The AI Act is the European regulation on artificial intelligence (Regulation (EU) 2024/1689). It classifies AI systems according to the risk they pose to people and assigns proportionate obligations: some uses are prohibited, others are allowed subject to strict requirements, and most require only transparency or no specific obligation at all. It applies both to those who develop AI systems and to companies that use them, regardless of size.
This guide is for information only and is not a substitute for legal advice. Dates are up to date as of November 2026: before making formal decisions, check them against the official texts listed at the end.
The four risk levels
| Level |
What it means |
Examples |
| Unacceptable risk |
Prohibited |
Social scoring of individuals, manipulation that exploits vulnerabilities, emotion recognition in the workplace and in schools (with some exceptions), untargeted scraping of facial images to build databases |
| High risk |
Allowed with strict obligations |
Recruitment and staff evaluation, access to credit, education, essential public services, safety components of regulated products |
| Limited risk |
Transparency obligations |
Chatbots, voice assistants, AI-generated or manipulated content, deepfakes |
| Minimal risk |
No specific obligations |
Spam filters, product recommendations, spell checkers, most internal uses |
Most SMEs use minimal- or limited-risk systems. High risk concerns those who use AI for decisions that significantly affect people, such as hiring, granting credit or assessing students.
The updated timeline
| Date |
What applies |
| 1 August 2024 |
The regulation enters into force |
| 2 February 2025 |
Prohibited practices and AI literacy |
| 2 August 2025 |
Rules on general-purpose AI models, governance and the penalties regime |
| 2 August 2026 |
Transparency obligations (Article 50) and most of the other provisions |
| 2 December 2026 |
End of the transition period for marking generated content, for systems already on the market before 2 August 2026 |
| 2 December 2027 |
Obligations for Annex III high-risk systems (after the Digital Omnibus) |
| 2 August 2028 |
Obligations for high-risk systems embedded in regulated products, Annex I (after the Digital Omnibus) |
What the Digital Omnibus changed
The Digital Omnibus on AI, proposed by the Commission on 19 November 2025 and adopted by the Council in June 2026, simplified some parts of the AI Act. The main changes for businesses:
- High-risk postponement: obligations for Annex III systems move from 2 August 2026 to 2 December 2027; those for systems embedded in regulated products under Annex I move to 2 August 2028.
- AI literacy reworded: the training obligation remains, but in a more flexible form, focused on supporting people’s skills according to how AI is actually used.
- New explicit prohibitions, such as the ban on applications that generate non-consensual nude images.
The postponement does not apply to the prohibitions, the rules on general-purpose models or the transparency obligations.
What changes for companies using chatbots and voice assistants
Since 2 August 2026, AI systems that interact directly with people must be designed so that those people know they are talking to an artificial intelligence, unless this is obvious from the context. The obligation falls on the provider of the system, but it also closely concerns anyone who uses it with their own customers. In practice:
- a chatbot on your website or on WhatsApp must introduce itself as a virtual assistant;
- an AI phone assistant should say so at the start of the call;
- AI-generated content, such as images, audio and video, must be marked in a recognisable way by whoever produces it, and deepfakes must be disclosed by whoever distributes them.
We cover this in our guide to AI phone assistants.
Provider or deployer: which role do you have?
- The provider develops an AI system, or has it developed, and places it on the market under its own name.
- The deployer uses an AI system under its own authority for its own activities.
A company that uses a third-party chatbot or assistant is generally a deployer. A company that builds an AI system and sells it to customers is a provider. The roles can overlap: if you substantially modify a system or use it for a high-risk purpose, you may take on provider obligations.
AI literacy: what it means in practice
Providers and deployers of AI systems must ensure that the people using them have adequate skills. No specific certificate is required: what you need is to be able to show that the measures you have taken are consistent with actual use. For example:
- an internal rule on which tools to use and with which data;
- short training on limitations, typical errors and risks;
- clear instructions on when a person needs to check the output.
Our guide on how to use ChatGPT, Claude and Gemini without exposing your data is a good starting point.
Penalties
The AI Act provides for fines of up to €35 million or 7% of worldwide annual turnover for prohibited practices, up to €15 million or 3% for breaches of other obligations, and up to €7.5 million or 1% for supplying incorrect information to the authorities. For SMEs, the lower of the fixed amount and the percentage applies.
Italy’s artificial intelligence law
In Italy, the AI Act is complemented by Law No. 132 of 23 September 2025, in force since 10 October 2025. The law:
- designates AgID, the Agency for Digital Italy (promotion, notification and accreditation), and ACN, the National Cybersecurity Agency (supervision, inspections and penalties), as the national AI authorities;
- introduces principles and disclosure obligations in specific areas, such as employment and the regulated professions;
- empowers the Government to adopt implementing decrees on a range of issues.
Six-step checklist
- Take inventory: which AI systems you use, for what, with which data and from which provider.
- Classify the risk of each one: prohibited, high, limited or minimal.
- Get transparency in order for chatbots, voice assistants and generated content: it is already mandatory.
- Train the people who use AI, in proportion to how they use it.
- Check your contracts with providers: roles, data processing, available documentation.
- Document your choices: a simple register of systems, risks and measures helps in the event of inspections and prepares you for the high-risk deadlines.
If you are integrating AI into your processes or into services for your customers, we can design it to be secure and transparent from the start.