Last verified 27 October 2026. One dated page on where the EU AI Act actually stands: what applies today, what was deferred and to when, where the harmonised standards are, and how the Italian framework lines up with the European one. We keep this page current because our own work depends on it.
This is a reference page, not legal advice. For how we work on the AI Act, see EU AI Act Readiness and AI Governance.
The calendar
Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force on 27 July 2026 and moved the high-risk obligations in Chapter III, Sections 1 to 3, to 2 December 2027 for stand-alone Annex III systems and to 2 August 2028 for AI embedded in products already covered by EU harmonisation law. Everything else runs on its original schedule. Reading the Omnibus as a general reprieve is the expensive mistake of this autumn.
Regulatory reference
Updated 27 October 2026
| Provision | Applies from |
|---|---|
| Art. 5 · prohibited practices | 2 February 2025 |
| Chapter V · GPAI obligations | 2 August 2025 |
| Art. 50 · transparency | 2 August 2026 |
| Chapter IX · market surveillance (Art. 75, 75a–75d) | 2 August 2026 |
| Art. 50(2) · marking of systems already on the market | 2 December 2026 |
| Chapter III, Sections 1–3 · Annex III stand-alone high-risk | 2 December 2027 |
| Chapter III, Sections 1–3 · Annex I embedded high-risk | 2 August 2028 |
Harmonised standards (status 27 October 2026). EN 18286:2026 (quality management system, Art. 17) is the first harmonised standard for the AI Act cited in the Official Journal, by Commission Implementing Decision (EU) 2026/2274 published on 14 October 2026. From that date, providers that apply it are presumed to conform to the requirements it covers, under Article 40. No harmonised standard has been cited yet for the other requirements. ISO/IEC 42001:2023, ISO/IEC 23894:2023, ISO/IEC 42005:2025 and ISO/IEC 12792:2025 are published and usable as a foundation. An ISO/IEC 42001 certificate does not equal AI Act compliance.
\n\nHarmonised standards
Compliance sits on two layers: what the Regulation requires, and which technical standard tells you how to satisfy it. The second layer is the unstable one, and it is where most of the confusion in the market comes from.
Italy
The two implementing decrees under Law 132/2025, Atti del Governo 421 and 418, were approved in final form by the Council of Ministers on 4 August 2026, eight days after the Digital Omnibus changed the European calendar. The first of the two is now in the Gazzetta Ufficiale: Legislative Decree 9 September 2026, no. 160, published in Gazzetta Ufficiale no. 214 of 15 September 2026, enters into force on 30 September 2026. It covers the use of AI systems in police activity and civil and criminal liability, and it reaches beyond policing: a new Article 25-vicies of Legislative Decree 231/2001 brings AI-related offences into the corporate liability regime, and new procedural instruments narrow the evidentiary gap for anyone harmed by an AI system. Atto del Governo 421, the governance decree that designates AgID as notifying authority and ACN as market surveillance authority and single point of contact, was published as Legislative Decree 7 October 2026, no. 179, in Gazzetta Ufficiale no. 234 of 8 October 2026, and has been in force since 23 October 2026.
How this page is maintained
Two items on this page can change at any moment, and both are checked every week: the Italian implementing acts in the Gazzetta Ufficiale, and the citation of further harmonised standards in the Official Journal of the European Union. When either moves, the text, the diagrams and the log below are updated on the same day.
Updates
27 October 2026. EN 18286:2026 on quality management systems is the first harmonised standard for the AI Act cited in the Official Journal of the European Union, by Commission Implementing Decision (EU) 2026/2274 of 12 October 2026, published and in force on 14 October 2026. Providers that apply it are presumed to conform to the requirements it covers; for the other requirements of Chapter III no harmonised standard has been cited yet. Legislative Decree no. 179/2026 entered into force on 23 October 2026. Article 4 on AI literacy, as replaced by Regulation (EU) 2026/1744 from 27 July 2026, requires providers and deployers to take measures to support the AI literacy of their staff, without requiring a specific level for each individual.
11 October 2026. The second Italian implementing decree is in the Gazzetta Ufficiale. Legislative Decree 7 October 2026, no. 179, formerly Atto del Governo 421, was published in Gazzetta Ufficiale no. 234 of 8 October 2026. It governs the powers of the national authorities, with AgID as notifying authority and ACN as market surveillance authority, and the use of AI systems in training and in employment. EN 18286:2026 has still not been cited in the Official Journal of the European Union, so the presumption of conformity under Article 40 remains unavailable to everyone.
21 September 2026. The first of the two Italian implementing decrees under Law 132/2025 is in the Gazzetta Ufficiale. Legislative Decree 9 September 2026, no. 160, formerly Atto del Governo 418, was published in Gazzetta Ufficiale no. 214 of 15 September 2026 and enters into force on 30 September 2026. It governs the use of AI systems in police activity and civil and criminal liability, and a new Article 25-vicies of Legislative Decree 231/2001 extends corporate liability to AI-related offences. Atto del Governo 421, the governance decree designating AgID as notifying authority and ACN as market surveillance authority, is still awaiting publication, with the delegation expiring on 10 October 2026. EN 18286:2026 has still not been cited in the Official Journal of the European Union, so the presumption of conformity under Article 40 remains unavailable to everyone.
\n\n31 August 2026. Re-verified the two items on this page that can move. The Italian implementing decrees under Law 132/2025, Atti del Governo 421 and 418, were approved in final form by the Council of Ministers on 4 August 2026 and are still awaiting publication in the Gazzetta Ufficiale, so the Italian adaptation is not yet in force. EN 18286:2026 has still not been cited in the Official Journal of the European Union, so the presumption of conformity under Article 40 remains unavailable to everyone. No substantive change to the guidance on this page.
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