EU AI Act enforcement and transparency rules start as AI Omnibus delays high-risk rules
The EU AI Act became applicable on 2 August 2026, when the European Commission's AI Office and national authorities began enforcing it and its transparency rules for chatbots, deepfakes and AI-generated content took effect, according to the Commission and Help Net Security. The AI Omnibus amendments, proposed on 19 November 2025, agreed on 7 May 2026 and in force since 27 July 2026, set 2 December 2027 for Annex III high-risk systems and 2 August 2028 for high-risk AI embedded in regulated products. Help Net Security reported that ignoring the transparency obligations risks fines of up to €15 million or 3% of worldwide annual turnover, whichever is higher.
- EU AI Act
- AI Office
- AI Omnibus
- AI transparency
- general-purpose AI
- deepfakes
What the sources report
- From 2 August 2026 the AI Office holds enforcement powers over general-purpose AI models: it can request technical documentation, evaluate models, require corrective measures and issue fines (European Commission).
- Under the transparency rules, chatbots must identify themselves as automated, deepfakes need a label and machine-made or edited content must carry machine-readable marks. The Commission published transparency guidelines on 20 July 2026, and Help Net Security reported that the Commission released a first list of over 180 organisations that signed the voluntary Code of Practice on transparency of AI-generated content.
- High-risk obligations, which now apply from 2 December 2027 for Annex III systems and from 2 August 2028 for AI embedded in regulated products, include logging of activity for traceability and a high level of accuracy, resilience and cybersecurity. Providers and deployers will also report serious incidents and malfunctioning.
- According to Help Net Security, the Commission said providers of the most advanced general-purpose AI models must address risks including cyber offence, loss of control and harmful manipulation.
- From 2 December 2026 the AI Omnibus adds a ninth prohibited practice, AI systems that generate non-consensual sexually explicit content or child sexual abuse material. According to the Commission's AI Act Service Desk, the same date is the transitional deadline for certain providers of generative AI systems already placed on the market before 2 August 2026 to comply with the Article 50(2) marking duty.
- In a Help Net Security interview, Veeam Field CTO Edwin Weijdema said simulated phishing and vishing exercises that use AI-generated content or cloned voices are not automatically exempt from the transparency requirements, and that the reasoning should be documented with legal and compliance input.
What it means for your organisation
Enforcement now covers general-purpose model providers and transparency duties that reach everyday deployments such as customer chatbots and generated media. Security testing is affected too: as Veeam's Edwin Weijdema pointed out, AI-generated lures and cloned voices in social engineering exercises are not automatically exempt from the transparency rules, so the legal position needs to be documented.
What we check
- Check whether an inventory of AI systems and models in use exists, classified as GPAI-based, Article 50 transparency-relevant or potential Annex III high-risk, each with an owner.
- Test customer-facing chatbots and AI agents for AI disclosure, prompt injection, data leakage and unsafe tool use, and keep the results as compliance evidence.
- Review logging for LLM applications and agents so each action can be traced to an identity, input and approval ahead of the December 2027 high-risk duties.
- Review social engineering engagement plans that use synthetic voices, deepfakes or AI-generated lures for legal sign-off, disclosure and debrief arrangements.
Sources
- AI Act (opens in a new tab) · European Commission · 19 October 2026
- AI Omnibus enters into force (opens in a new tab) · European Commission · 27 July 2026
- EU agrees to simplify AI rules to boost innovation and ban 'nudification' apps to protect citizens (opens in a new tab) · European Commission · 7 May 2026
- Timeline for the implementation of the EU AI Act (opens in a new tab) · European Commission, AI Act Service Desk
- Guidelines on transparency obligations for providers and deployers of certain AI systems (opens in a new tab) · European Commission · 6 August 2026
- EU begins enforcing AI Act, putting AI models under the microscope (opens in a new tab) · Help Net Security · 4 August 2026
- What the first year of EU AI Act transparency enforcement could look like (opens in a new tab) · Help Net Security · 7 August 2026