EU AI Act Key Dates for Employers in Ireland: The Timetable After the Omnibus

The EU AI Act applies in stages, and the timetable changed in 2026. As of 9 October 2026, the European Commission's regulatory framework page (last updated 3 August 2026) lists these dates: entry into force on 1 August 2024, prohibited practices and AI literacy from 2 February 2025, governance and general-purpose AI obligations from 2 August 2025, general applicability from 2 August 2026, and high-risk rules for Annex III uses from 2 December 2027. This guide sets out the EU AI Act key dates for employers, shows which source supports each one, and flags where the sources disagree. It is general information, not legal advice.

Many employers will be most interested in the AI literacy duty, the rules for AI used in HR, and the transparency provisions. For the latter, see our explainer on Article 50 transparency and labelling obligations.

The timetable at a glance

What changed in 2026

The Commission's page says the Digital Package on Simplification, which proposed the amendments to the AI Act, was adopted on 19 November 2025, that political agreement on the AI Omnibus was reached on 7 May 2026 and that it entered into force on 27 July 2026. EUR-Lex shows Regulation (EU) 2026/1744 as adopted on 8 July 2026 and published in the Official Journal on 24 July 2026, and its recital 46 says it takes effect on the third day after publication, which is consistent with 27 July.

The main effect for employers is that the Annex III high-risk rules, which include AI used in employment and worker management, were pushed to 2 December 2027, and the Annex I product rules to 2 August 2028. The AI Office of Ireland's page for the Data Protection Commission describes the Annex III change as a 16-month extension from an original date in 2026. Other changes listed by the Commission include a new prohibition on nudification and similar content, stronger AI Office powers and simplified requirements for small mid-cap companies.

The Commission's AI literacy Q&A page adds that the Omnibus amended Article 4, which remains an obligation but does not mandate a specific level of literacy.

What each date means for an employer

Since 2 February 2025: AI literacy and prohibitions

Article 4 requires providers and deployers to take measures to support the AI literacy of their staff and others using AI on their behalf. The Commission's Q&A says no certificate is needed and employee knowledge need not be measured. The prohibitions also apply. The Workplace Relations Commission's page says it has a market surveillance role for certain prohibited practices, including AI that infers emotions of workers or job applicants, except in limited permitted circumstances.

Since 2 August 2025: governance and general-purpose AI

These mainly concern providers of general-purpose AI models and the governance structure, rather than employers who simply use AI tools. The Service Desk text of Article 113 also lists other chapters starting on this date, except Article 101.

From 2 August 2026: general application and supervision

The Commission's skills page says national market surveillance authorities begin supervising and enforcing Article 4 on 2 August 2026. The Commission's Q&A page gives both 2 August 2026 and 3 August 2026 in different places, so check the current version of that page. The Commission's regulatory framework page also lists transparency rules as taking effect in August 2026, without further detail on the page we read, so check the Act's wording for any particular transparency duty before relying on a date.

2 December 2027 and 2 August 2028: high-risk

If you use AI for recruitment, promotion, task allocation or monitoring of workers, Annex III point 4 is the relevant category, and the Commission's page gives 2 December 2027. Deployer duties such as informing workers' representatives and affected workers are set out in Article 26 and follow the high-risk dates. Annex III point 4 and Article 26 can be read on the Commission's AI Act Service Desk.

Ireland's implementation

The Department of Enterprise, Tourism and Employment announced on 17 June 2026 that the Government had approved publication of the Regulation of Artificial Intelligence Bill 2026, describing it as giving effect to the AI Act in Ireland and adding no obligations beyond the EU Regulation. The Workplace Relations Commission's AI Act page says the Regulation of Artificial Intelligence Act 2026 became law on 21 July 2026 and that further legislation for its supervisory powers is expected. The AI Office of Ireland lists the designated national competent authorities, including the Data Protection Commission, the Central Bank of Ireland and the Workplace Relations Commission. We have not read the Act itself, so we do not state its penalties or commencement arrangements.

Where the sources disagree

• Entry into force: the Commission page says 1 August 2024. The Department of Enterprise page "The EU AI Act and my organisation" says 2 August 2024. We have used 1 August 2024, in line with the Commission and the Department's own press release.
• Omnibus entry into force: the Commission regulatory framework page says 27 July 2026. The AI literacy Q&A refers to mid-July 2026.
• Number of Irish authorities: the WRC page says 15; the AI Office of Ireland lists 13.

A practical approach (our suggestions)

• Treat the AI literacy duty as the live item and plan staff support now, because it applies today.
• List your AI tools and note which could fall under Annex III. Revisit the list before December 2027.
• Put a recurring review into your calendar, because this timetable moved in 2026 and could move again.
• Rely on the Commission's regulatory framework page, the AI Act Service Desk and the AI Office of Ireland for updates, and take legal advice for decisions with real consequences.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

When did the EU AI Act enter into force?

The Commission says 1 August 2024. One Irish government page says 2 August 2024, so we flag the discrepancy.

Are the high-risk rules delayed?

Yes. The Commission's page, updated 3 August 2026, gives 2 December 2027 for Annex III use cases and 2 August 2028 for Annex I products, following the Digital Omnibus on AI.

Is the AI literacy duty already in force?

Yes. The Commission lists AI literacy among the obligations that applied from 2 February 2025, and says national authorities supervise it from 2 August 2026.

Could the dates change again?

We cannot say. The dates above are those shown on the pages we read, and they changed during 2026. Check the Commission and AI Office of Ireland before acting.

Where can I check the legal text?

The Regulation is published on EUR-Lex. Regulation (EU) 2026/1744 amends Regulation (EU) 2024/1689, and the Commission's AI Act Service Desk shows a text based on the EUR-Lex consolidated version as at 27 July 2026; check EUR-Lex for the authoritative text.

The timetable is staggered, so the useful question for each tool is which date applies to the way you use it. Our guide to GDPR staff training for employers covers a related duty that already applies.