SkarpChapter 23 of 25
Transition, Application and the Act’s Legal Reference Network
The operative text closes with transition rules, evaluation duties and a staged timetable rather than a single compliance date. The accompanying footnotes reveal the dense legal network—from data protection and product safety to copyright and whistleblower law—on which the Act relies.
Map the Closing Provisions
Three Closing Functions
Articles 111-113 do three different jobs: transition for legacy systems, recurring evaluation, and staged application. Read them as connected, but do not treat them as one universal deadline.
A Timeline, Not a Switch
Visualize three lanes: legacy AI, Commission review, and application dates. Which lane applies depends on the system, the actor, the date, and sometimes design changes.
Currency Note
As of 22 July 2026, PE-CONS 30/26, dated 8 July 2026, is signed pending publication and not in force. The source wording remains the rule taught in this module.
Article 111(1): Large-Scale IT Systems
Who Is Covered?
Article 111(1) concerns AI systems that are components of large-scale IT systems established by legal acts listed in Annex X, where the AI system was placed on the market or put into service before 2 August 2027.
The Exact Deadline
The source requires that these systems "shall be brought into compliance with this Regulation by 31 December 2030". This is mandatory and is limited to the Article 111(1) category.
Evaluation Link
The Regulation's requirements shall be taken into account in each relevant system evaluation under its founding legal act, including when that act is replaced or amended.
Article 111(2): Existing High-Risk Systems
Conditional Rule for Legacy Systems
For covered high-risk systems placed on the market or put into service before 2 August 2026, Article 111(2) applies only if the system is subject to significant changes in its designs from that date.
Do Not Add a Definition
This excerpt does not define significant changes in their designs. Do not substitute a personal threshold, such as a new feature or a retrained model, for the source's unstated test.
Public-Authority Backstop
For high-risk AI intended for public authorities, providers and deployers shall take the necessary steps to comply by 2 August 2030. The text says "In any case".
Classify the Transition Path
Thought exercise: which Article 111 route applies?
For each scenario, identify the most relevant sentence from Article 111. Then identify what the source does not tell you.
- An AI component of an Annex X large-scale IT system entered service in May 2027.
- Which date controls its compliance route?
- What additional process must take account of the Regulation's requirements?
- A high-risk AI system entered service in January 2026 for a private company. Its design is not significantly changed after 2 August 2026.
- Does the first sentence of Article 111(2) state that the Regulation applies merely because the system is high risk?
- Which missing fact would matter if the answer changed?
- A high-risk AI system was placed on the market in 2024 and is intended for a municipal authority.
- Which actors are named?
- What is their date for taking the necessary compliance steps?
- A general-purpose AI model was placed on the market on 1 August 2025.
- Which Article 111 paragraph applies?
- What does that paragraph require?
Self-check
- Scenario 1: Article 111(1); compliance by 31 December 2030, with requirements taken into account in the relevant system evaluation.
- Scenario 2: Article 111(2) makes application conditional on significant design changes from 2 August 2026. The excerpt does not supply the test for significance.
- Scenario 3: providers and deployers; necessary steps by 2 August 2030.
- Scenario 4: Article 111(3); necessary steps to comply with the Regulation's obligations by 2 August 2027.
Article 111(3): Existing General-Purpose AI Models
The Exact Article 111(3) Rule
"Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027."
Keep the Categories Separate
Article 111(3) names providers and general-purpose AI models. It does not use the public-authority wording of paragraph 2 or the Annex X large-scale IT wording of paragraph 1.
Read "Before" Precisely
A model placed on 1 August 2025 fits a cutoff of before 2 August 2025. A model placed on 2 August 2025 is not described by those exact words.
Article 112(1)-(5): The Review Architecture
Annual Assessment
Article 112(1) requires the Commission to assess annually whether Annex III and Article 5 should be amended, then submit its findings to Parliament and the Council.
2028 Review Cycle
By 2 August 2028 and every four years thereafter, the Commission shall report on Annex III headings, Article 50 transparency systems, and improvements to supervision and governance.
2029 Review Cycle
By 2 August 2029 and every four years thereafter, a public report must assess enforcement structure and the possible need for a Union agency, with an amendment proposal where appropriate.
Evidence the Reports Must Consider
Paragraph 4 focuses on authority resources, penalties, harmonised standards and common specifications, and new market entrants, including the number that are SMEs.
Article 112(6)-(13): Evidence, Standards and Amendment
Energy and Voluntary Codes
By 2 August 2028, the Commission must review energy-efficient general-purpose AI standardisation. It must also evaluate voluntary codes of conduct by that date, then every three years.
Information Must Flow
The Board, Member States, and national competent authorities shall provide requested information to the Commission without undue delay under Article 112(8).
Methodology and Sectoral Specificity
The AI Office is to develop an objective and participative risk-evaluation methodology. Changes concerning Annex I Section B must account for each sector's regulatory specificities and established mechanisms.
2031 Enforcement Assessment
By 2 August 2031, the Commission shall assess enforcement and report to Parliament, the Council, and the European Economic and Social Committee, with an amendment proposal where appropriate.
Quiz: Match the Review Cycle
Choose the statement that accurately reflects Article 112.
Which statement is correct under Article 112?
- The Commission must submit its first general evaluation-and-review report by 2 August 2029, and every four years thereafter; the reports shall be made public.
- The AI Office may provide information to the Commission if convenient, but national authorities have no stated duty to do so.
- Voluntary codes of conduct for non-high-risk AI systems must be evaluated annually from entry into force.
- The Commission must create a Union agency by 2 August 2028.
Show Answer
Answer: A) The Commission must submit its first general evaluation-and-review report by 2 August 2029, and every four years thereafter; the reports shall be made public.
Article 112(3) requires the report by 2 August 2029 and every four years thereafter, and states that the reports shall be made public. Paragraph 8 imposes a duty to provide requested information without undue delay. Paragraph 7 uses a three-year, not annual, cycle. The text requires assessment of the possible need for a Union agency; it does not require creating one.
Article 113: Entry into Force and Staged Application
General Rule
Article 113 provides: "It shall apply from 2 August 2026." Entry into force is separately set for the twentieth day following publication in the Official Journal.
Earlier Application
"Chapters I and II shall apply from 2 February 2025". Other named provisions applied from 2 August 2025, while Article 6(1) and corresponding obligations apply from 2 August 2027.
External Currency Note
PE-CONS 30/26 is signed pending publication, not in force on 22 July 2026. Thus the source timetable remains applicable today, despite proposed postponements for specified high-risk categories.
Legal Effect
"This Regulation shall be binding in its entirety and directly applicable in all Member States." Article 113 states this directly; it is not a recommendation or a national transposition timetable.
The Footnotes: A Legal Reference Network
Data and Platform Context
The references include the GDPR and Digital Services Act. Their presence shows that AI governance sits beside rules on personal-data processing and digital services, rather than replacing them in this excerpt.
Sectoral Context
The source connects AI to critical-entity resilience, medical devices, and civil aviation. These references show why Article 112(12) requires attention to sector-specific governance and enforcement.
Implementation Context
Standardisation, data access, the AI Office, whistleblower protection, and trade secrets appear in the legal network. They point to how compliance, oversight, reporting, and confidentiality can intersect.
External Medical-Device Note
COM(2025) 1023 final, dated 16 December 2025, is only a proposal on 22 July 2026. It does not change the source wording or current legal classification taught in this lesson.
Quiz: Identify the Correct Deadline
Use the exact wording and scope of Articles 111 and 113.
A provider placed a general-purpose AI model on the market on 1 August 2025. Which answer best follows the source text?
- The provider shall take the necessary steps to comply with the obligations laid down in the Regulation by 2 August 2027.
- The provider must bring the model into compliance by 31 December 2030 because all legacy AI uses that date.
- The provider is covered only if the model undergoes significant design changes after 2 August 2026.
- The provider has no stated transition obligation because the general application date is 2 August 2026.
Show Answer
Answer: A) The provider shall take the necessary steps to comply with the obligations laid down in the Regulation by 2 August 2027.
Article 111(3) applies to providers of general-purpose AI models placed on the market before 2 August 2025 and sets 2 August 2027. The 31 December 2030 date belongs to Article 111(1) large-scale IT systems. The significant-design-change condition belongs to Article 111(2) for specified high-risk systems. The general application date does not remove the specific Article 111(3) transition rule.
Flashcards: Dates, Actors and Legal Effects
Flip each card, say the answer aloud, and then explain why nearby dates do not replace it.
- Article 111(1): deadline for covered Annex X large-scale IT system AI components
- They **"shall be brought into compliance with this Regulation by 31 December 2030"**, if placed on the market or put into service before 2 August 2027.
- Article 111(2): condition for many pre-2 August 2026 high-risk systems
- The Regulation applies only if, from 2 August 2026, those systems are subject to **significant changes in their designs**.
- Article 111(2): public-authority high-risk systems
- Providers and deployers **shall take the necessary steps** to comply by 2 August 2030.
- Article 111(3): older general-purpose AI models
- Providers of models placed on the market before 2 August 2025 shall take necessary steps to comply by 2 August 2027.
- Article 112: first general evaluation-and-review report
- By 2 August 2029, and every four years thereafter; it includes enforcement structure and possible need for a Union agency.
- Article 113: general application date
- **"It shall apply from 2 August 2026."**
- Article 113: earlier application of Chapters I and II
- **"Chapters I and II shall apply from 2 February 2025"**.
- Article 113: legal effect in Member States
- **"This Regulation shall be binding in its entirety and directly applicable in all Member States."**
Key Terms
- SME
- Small and medium-sized enterprise. Article 112(4)(d) requires attention to how many undertakings entering the market after application are SMEs.
- Annex X
- The annex referenced in Article 111(1) for legal acts establishing the relevant large-scale IT systems. This excerpt does not list those legal acts.
- Deployer
- An actor expressly named with providers in Article 111(2)'s rule for high-risk AI systems intended to be used by public authorities.
- AI Office
- The body evaluated under Article 112(5) and assigned a methodological task under Article 112(11). The source footnotes cite Commission Decision of 24.1.2024 establishing the European Artificial Intelligence Office C(2024) 390.
- Annex III
- The list referred to in Article 112 as subject to recurring Commission assessment and possible amendment. This excerpt does not reproduce its contents.
- Article 5
- The provision identified in Article 112(1) as containing the list of prohibited AI practices. Article 111 is without prejudice to its application as referred to in Article 113(3), point (a).
- Article 6(1)
- A provision whose application, together with corresponding obligations, is scheduled in Article 113(c) from 2 August 2027 under the source text.
- Directly applicable
- Article 113 states that the Regulation is binding in its entirety and directly applicable in all Member States.
- High-risk AI system
- A category addressed in Article 111(2). For covered legacy systems, applicability depends on significant design changes, while systems intended for public authorities have a separate 2 August 2030 compliance-step deadline.
- Harmonised standards
- Standards that Article 112(4)(c) requires the Commission's reports to examine once adopted, alongside common specifications developed to support the Regulation.
- General-purpose AI model
- The model category addressed by Article 111(3) for providers whose models were placed on the market before 2 August 2025.
- Significant changes in their designs
- The condition in Article 111(2) for application to specified high-risk AI systems placed on the market or put into service before 2 August 2026. This excerpt does not define the phrase.