Watching

EU AI Act

Last reviewed 23 Sep 2026

Tracking the obligation timeline and what it means for Swiss firms that serve EU clients.

What to watch

State of 14 Oct 2026, after the Digital Omnibus on AI (Regulation 2026/1744, in force since 27 Jul 2026).

High-risk rules moved. Annex III systems (HR, credit scoring, education, critical infrastructure) now apply from 2 Dec 2027, AI in regulated products (Annex I) from 2 Aug 2028. Use the time for documentation and the quality management system.
Already in force: the bans and AI literacy (since Feb 2025), general-purpose AI rules (since Aug 2025) and the Article 50 transparency duties (since Aug 2026). AI literacy is now "take measures", not "guarantee a level".
2 Dec 2026 is next. Two new bans (AI-generated child abuse material and non-consensual intimate images), and the end of the grace period for machine-readable marking of generated content in systems already on the market.
Provider or deployer decides your load. Put your name on a system, modify it substantially or change its purpose, and you become the provider (Art. 25). Settle the role in every client contract.
Switzerland has no AI act. The FADP and FINMA Guidance 08/2024 apply now; a consultation draft to ratify the Council of Europe convention is due by end of 2026.
Swiss firms are in scope anyway when an AI system or its output is used in the EU (Art. 2). Build to the EU Act as the baseline.
Fines: up to €35 million or 7% for bans, €15 million or 3% for most other duties, lower caps for SMEs.
Expect more change. The dates moved once already; check the Official Journal, not summaries.

The long version is the blog post below. Not legal advice.

14 Oct 2026 Added a short list of what to watch, checked against the Omnibus dates. Status unchanged.
2 Jul 2026 Reviewed. No change.