The EU AI Act reaches an important milestone on 2 August 2026, when new transparency requirements take effect.
These include obligations affecting certain customer-facing AI systems, chatbots, deepfakes and AI-generated or manipulated content. Although the implementation dates for substantial parts of the high-risk AI regime have been extended, the transparency deadline has not moved, and the existing AI literacy requirements remain relevant.
The Act is not relevant only to major technology companies or businesses established in the EU. It may also affect UK businesses that develop, integrate, white-label or supply AI-enabled products into the EU, or whose AI outputs are used there. Technology and SaaS providers are the clearest examples, but businesses using AI in recruitment, workforce management, healthcare, financial services, education, customer service or content creation may also need to consider their position.
Businesses should now:
- identify where AI is being used across the organisation, including functionality embedded within third-party software;
- establish whether they are developing, supplying or deploying each AI system;
- consider whether there is a relevant EU connection;
- review customer disclosures, staff training and internal governance; and
- review contractual arrangements, particularly customer and supplier contracts containing broad EU AI Act warranties, compliance obligations or indemnities.
Customer and supplier contracts require particular attention, especially where they contain broad EU AI Act warranties, compliance obligations or indemnities.
If you are unsure whether the Act applies to your business, now is the time to find out.
Our commercial technology solicitors can help UK businesses assess whether the EU AI Act applies to them and how prepared they are for its requirements. This may include mapping how AI is used across the organisation, developing proportionate governance and staff policies, and reviewing English-law customer and supplier contracts to ensure that AI-related responsibilities and risks are allocated appropriately.
Where specialist EU or individual Member State advice is needed, we can identify the relevant issues and work alongside suitably qualified EU advisers.
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