EU & Spain AI Regulatory Calendar: Every Confirmed Deadline
Short answer: The table below lists every EU AI Act deadline currently confirmed in force or in law, plus Spain-specific developments, in chronological order. It distinguishes dates that are confirmed and binding from developments that are proposed but not yet adopted — a distinction a lot of AI Act commentary collapses, especially after the July 2026 Digital Omnibus moved several dates that earlier articles still describe as fixed.
Last reviewed: 19 August 2026. This page will be updated as new dates are confirmed, amended, or adopted — check the "last reviewed" date above before relying on any figure here for a filing or compliance decision, and verify against the primary sources linked below.
> Confirmed and already in force
| Date | What applies | Detail |
|---|
| 2 February 2025 | EU AI Act prohibited practices (Article 5) | Certain AI uses banned outright across the EU. |
| 2 August 2025 | GPAI model obligations begin | New general-purpose AI models placed on the market from this date must comply. |
| 18 February 2026 | AEPD agentic AI guidance published | 81-page Spanish guidance on GDPR risks specific to autonomous AI agents. |
| 27 July 2026 | Digital Omnibus on AI enters into force | Defers high-risk system obligations (see below); does not touch Article 50. |
| 2 August 2026 | EU AI Act Article 50 transparency duties | AI-interaction disclosure and AI-generated-content labeling. Not deferred by the Omnibus. |
| 2 August 2026 | GPAI enforcement powers activate | Fines up to €15M or 3% of global turnover for non-compliant GPAI providers. |
> Confirmed, still ahead
| Date | What applies | Detail |
|---|
| 2 December 2026 | Article 50(2) watermarking deadline | Narrower technical implementation window, separate from the general Article 50 disclosure duty already live since August 2026. |
| 2 August 2027 | Legacy GPAI models must comply | Models placed on the market before 2 August 2025 lose their grace period. |
| 2 December 2027 | High-risk obligations — Annex III standalone systems | Recruitment, credit scoring, education, law enforcement and similar standalone high-risk categories. Deferred from the original 2 August 2026 date by the Digital Omnibus. |
| 2 August 2028 | High-risk obligations — Annex I embedded systems | AI embedded in products already covered by EU product-safety law (medical devices, machinery). Deferred by the Digital Omnibus. |
| 2 August 2030 | Pre-existing high-risk systems used by public authorities | Legacy systems in public-sector use must reach compliance. |
> Spain-specific — confirmed activity, law not yet passed
| Date | What happened | Status |
|---|
| June 2024 | AESIA (Spain's AI supervisory agency) becomes operational | In force — AESIA already runs sandbox cohorts and preliminary investigations. |
| 26 May 2026 | Council of Ministers approves draft Organic Law on AI governance | Approved as a bill, not yet enacted. |
| 12 June 2026 | Published in the Official Journal of the Parliament | Formal parliamentary process begins. |
| 30 June 2026 | Amendment period closes | Bill remains in committee as of this page's last review. |
| Pending | Organic Law enters into force | Would codify AESIA's sanctioning power — up to €35M / 7% of turnover for the most serious infringements. Not yet law. See our dedicated article on AESIA and the Organic Law. |
> Proposed, not yet adopted — do not treat as binding
| Development | Status | Detail |
|---|
| EU "Data Omnibus" (GDPR / ePrivacy / NIS2 / DORA) | In negotiation, not adopted | Proposed: 96-hour breach notification (up from 72h), single-click cookie consent with a 6-month refusal moratorium, one EU-wide DPIA list replacing 27 national lists. Realistic adoption window is late 2026 into 2027, not confirmed. |
> Sources
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