On August 2, 2026, the European Commission’s AI Office began exercising formal investigative and sanctioning powers under the AI Act, converting a two-year architecture of principle into an operational regime with teeth. Maximum penalties now sit at €15 million or 3% of global turnover for breaches by general-purpose AI providers, and €35 million or 7% for prohibited practices.

Article 50’s transparency duties activated the same day. Chatbots must disclose they’re AI unless the fact is obvious, deepfakes must be labelled, and AI-generated content must carry machine-readable provenance signals. In parallel, prohibitions on manipulative AI, exploitation of vulnerabilities, unfair social scoring, and profiling-only predictive policing became enforceable, alongside GPAI provider obligations on downstream transparency, copyright, and systemic-risk safety.

The Office’s toolkit is expansive: requests for information, model access and evaluation, corrective orders, market restrictions, on-site inspections, witness interviews. Per the Commission’s enforcement framework, incorrect, misleading, or missing responses to information requests can themselves draw fines. Wilson Sonsini notes that the Office has flagged “technical compliance dialogues” as its preferred first step, an approach the firm expects will “will continue, and may intensify” after August 2.

There’s a narrow carve-out. Cooley and Morgan Lewis both note that generative systems placed on the EEA market before August 2 have until December 2, 2026 to satisfy the marking-and-detection duty; deployer obligations aren’t deferred. Cooley also reports several major providers have already signed the AI Office’s voluntary Code of Practice on Transparency, buying a presumption of conformity.

More phases are locked in. CSAM and non-consensual intimate imagery prohibitions apply from December 2026, Annex III high-risk systems from December 2027, embedded high-risk products from August 2028. Brussels built the timeline years ago; the industry now discovers whether its lobbying delayed the substance or only the calendar.

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