GUIDE

The EU AI Act: what applies to your business, and when

The EU AI Act for business leaders: what already applies (prohibited practices, AI literacy, transparency), what has been postponed for high-risk, provider vs deployer, and the concrete steps to take now.

September 2026 · 7 min read

Guide · EU AI Act

The EU AI Act: what applies
to your business, and when

Europe's AI regulation is not just a matter for lawyers or large groups. It concerns any company that uses AI, including a small business running ChatGPT. This guide sorts it out, for a business leader: what already applies today, what has been postponed, and the concrete steps to take now. No jargon, and without turning your organization into a legal department.

YPrtnrs Institute · updated September 2026 · 9 min read
Read this as orientation, not legal advice. This guide helps a leader get their bearings and act. For the precise classification of your systems and your exact obligations, have your case reviewed by specialist counsel. The timeline below was amended in 2026 (the "Digital Omnibus" agreement) and is still being finalized.

What is the AI Act, in one sentence for a leader?

It is the European regulation that governs artificial intelligence by risk: the more a use can harm people, the stronger the obligations. It does not target model makers alone; it also applies to you, who use AI in your business. In force since 1 August 2024, it applies in stages through 2028.

The text sorts uses into four families: prohibited practices (manipulation, social scoring), high-risk uses (recruitment, scoring, critical infrastructure), limited-risk uses subject to transparency (chatbots, generated content), and everything else, at minimal risk, which is free. Most of a small or mid-sized company's uses fall into the last two families. Placing your uses on this grid is the real starting point, and it is also the first step of our method, augmented execution.

Prohibited High-risk recruitment, scoring, biometrics Limited risk · transparency chatbots, generated content Minimal risk · free drafting, summarizing, translating strong obligations few obligations
The four risk levels of the AI Act. Most of a smaller company's uses sit at the bottom of the pyramid.

What already applies today?

Three blocks are in force, and they already concern your business. Since February 2025: the prohibited practices and the AI literacy obligation. Since August 2025: the obligations for general-purpose AI models (GPAI). Since 2 August 2026: the transparency obligations of Article 50.

Two of them touch a leader who uses AI directly. AI literacy: any company that uses AI must make sure its people have a sufficient understanding of what they are handling. Transparency: a chatbot must disclose that it is an AI, and generated content (text, images, audio) must be flagged, with a machine-readable technical marking. A grace period runs until 2 December 2026 for that technical marking only, not for the chatbot disclosure.

AI literacy meets a problem you already know: AI enters the company through the teams, often without any framework. See how to structure that use in the guide on AI transformation.

What has been postponed?

The heaviest obligations, those for high-risk systems, have been pushed back. The original 2 August 2026 deadline was deferred by the 2026 "Digital Omnibus" agreement: high-risk systems under Annex III (recruitment, scoring, education, biometrics) now apply from 2 December 2027, and AI embedded in already-regulated products (medical devices, machinery) from 2 August 2028.

The delay removes nothing: documentation, risk management, human oversight and logging still have to be prepared, simply later. If one of your uses is affected, this window is a reprieve to get organized, not an exemption. And it touches neither the prohibitions, nor literacy, nor transparency, which do apply now.

1 Aug 2024
Regulation enters into force
2 Feb 2025
Prohibited practices + AI literacy in force
2 Aug 2025
General-purpose AI models (GPAI) in force
2 Aug 2026
Transparency (Article 50) in force
2 Dec 2027
High-risk · Annex III (recruitment, scoring…) postponed
2 Aug 2028
AI embedded in regulated products postponed
The AI Act application timeline, after the 2026 "Digital Omnibus" deferral.

Are you a "provider" or a "deployer"?

The distinction sets your obligations. A provider designs or places an AI system on the market. A deployer uses it in the course of business. A company that uses off-the-shelf AI tools is, in the vast majority of cases, a deployer: its obligations are real but far lighter than a maker's.
Provider (system maker)Deployer (your business, a user)
RoleDesigns, places on the marketUses AI in its business
Weight of obligationsHeavy (system conformity, technical documentation)Targeted: compliant use, transparency, literacy
What already appliesGPAI, documentation, marking at sourceAI literacy, chatbot disclosure, content flagging
High-risk (from 2027)Prove the system's conformityHuman oversight, use per instructions, logs

Watch one trap: by substantially modifying a system, or putting it out under your own brand, a deployer can be reclassified as a provider, with the obligations that come with it. Hence the value of knowing exactly what your teams use, and how.

Is your use "high-risk"?

Rarely, for everyday office use. High-risk, in the sense of Annex III, covers specific cases: screening job applications, deciding on access to credit or benefits, grading students, biometrics, the security of critical infrastructure. Drafting, summarizing, translating or preparing a meeting with AI does not fall into that category.

So the right question is not "do we use AI," but "what is each use for." The same tool can be harmless for drafting minutes and sensitive for shortlisting CVs. That is why everything starts with an honest map of your uses, including the ones nobody approved. The guide to use cases by sector helps spot where the sensitive uses sit in your line of work.

What penalties, and for whom?

The ceilings are high, but proportionate to severity and to company size. Prohibited practices carry up to 35 million euros or 7% of worldwide turnover. Other breaches, up to 15 million or 3%. For a smaller company, the ceilings are adjusted, but the risk is not zero.

What to take away is the order of priority they draw: never fall into a prohibited use, hold transparency and literacy now, and prepare for high-risk if you are concerned. The rest is good management, not fear.

What to do concretely, right now?

Five steps are enough to be compliant on what applies, and ready for the rest. They amount to a routine, not a grand program: map, train, make transparent, document, prepare.

1. Map your AI uses, including informal ones, team by team. 2. Document the training of your people (AI literacy). 3. Make chatbots visible and flag generated content (transparency). 4. Write a one-page set of rules: what is allowed, what never leaves, what always gets checked. 5. If a use is high-risk, use the reprieve until 2027 to prepare documentation and oversight.

The first two steps, mapping and placing your uses, are exactly what a diagnostic does. My Pulse establishes the state of your AI uses in ten minutes and surfaces the sensitive ones. It is the first brick of compliance as much as of transformation. Start with the AI maturity assessment.

Map your AI uses

My Pulse · state of your uses in 10 min · free · the first step toward compliance

Run my assessment

Frequently asked

Is a small business that only uses ChatGPT concerned by the AI Act?

Yes, but lightly. As a deployer, it must ensure its teams' AI literacy and transparency (disclose chatbots, flag generated content). These obligations already apply. High-risk, which is heavier, concerns it only if a specific use falls under Annex III.

Does using AI automatically make my business "high-risk"?

No. High-risk depends on the use, not the tool. Drafting, summarizing or translating is not high-risk. Screening applications or deciding on credit is. The same tool can be either, depending on what you do with it.

Do I need a lawyer or a DPO to become compliant?

Legal counsel usefully validates the sensitive cases. But most of the work is operational: knowing what your teams use, setting rules, documenting. It is an execution effort before it is a legal file.

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