Legal Q&A · IT, Software & E-commerce

When does the AI Act apply, and who does it cover?

Law as at 10 September 2026

Short answer

The AI Act applies progressively: the first general provisions and prohibitions from 2 February 2025, rules for general-purpose AI models from 2 August 2025, with 2 August 2026 remaining the general application date. Regulation (EU) 2026/1744, however, postponed Chapter III, Sections 1 to 3, except Article 6(5): until 2 December 2027 for high-risk systems under Annex III and until 2 August 2028 for systems linked to regulated products under Annex I. It covers providers and businesses deploying AI; their specific duties depend on their role and the system.

A directly applicable Regulation

The AI Act is Regulation (EU) 2024/1689 of the European Parliament and of the Council on artificial intelligence. As a Regulation, it is binding in its entirety and directly applicable in all Member States: no separate implementing Act is needed for it to apply in Slovakia. It entered into force on 1 August 2024, but its rules apply in stages.

When does the AI Act apply?

Article 113, as amended by Regulation (EU) 2026/1744, sets the timetable. The current dates are:

  • 2 February 2025: general provisions and prohibitions on certain AI practices (Chapters I and II).
  • 2 August 2025: rules for general-purpose AI models, such as large language models, and some governance and penalty provisions.
  • 2 August 2026: the general application date remains in place, but this does not mean that all rules for high-risk systems take effect at once.
  • 2 December 2027: Chapter III, Sections 1 to 3, except Article 6(5), for high-risk systems under Article 6(2) and Annex III.
  • 2 August 2028: the same group of obligations for systems under Article 6(1) linked to regulated products under Annex I.

For a specific system, the transitional rules in Article 111 must also be considered. Postponing the high-risk-system obligations does not automatically postpone the entire AI Act or its general transparency obligations.

Who does the AI Act cover?

Its scope is broad (Article 2). It applies particularly to providers placing an AI system or model on the Union market or putting it into service there, even if established in a third country, and to deployers using AI in their activities and established in the Union. It also covers providers and users outside the EU where the system’s output is used in the Union, as well as importers, distributors and manufacturers of products incorporating AI.

Exceptions include purely personal, non-professional use, systems exclusively for military and security purposes, pure scientific research and development, and generally free and open-source software unless it is a high-risk system or a system under Article 5 or 50. In practice, the AI Act covers ordinary companies using AI in recruitment, client assessment or marketing as well as technology businesses.

Which practices are already prohibited?

Since February 2025, certain practices are prohibited entirely under Article 5, including manipulative subliminal techniques, exploitation of vulnerabilities, social scoring, untargeted scraping of facial images from the internet, emotion recognition at work and in schools, and biometric categorisation by sensitive characteristics. Every company’s first step should therefore be to determine whether any tool it uses falls into a prohibited or high-risk category.

Our AI Act compliance service supports tool audits, risk classification, transparency duties and oversight. Since AI closely involves personal data, we usually combine this with GDPR and personal data protection and software licence terms.

This answer provides general information on the law as at 10 September 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.

More legal questions

All questions and answers
  1. How should we display discounts, and what is the lowest price in the previous 30 days? Every goods price reduction announcement must state the previous price, meaning the lowest price at which you sold the goods in the 30 days before the reduction (Section 7 of Act No. 108/2024 Coll.). The discount must also be calculated from that price, not the regular pre-promotion price. The Slovak Trade Inspection actively checks shops and websites, comparing price records with displayed prices. A struck-through price inconsistent with the history can lead to a fine.
  2. We sell online courses. Can our terms say course fees are non-refundable? Not in that form. A consumer buying remotely has a 14-day withdrawal right that cannot be waived in advance, so the clause is invalid and may attract a fine. The law offers digital content sellers a lawful route: the right ends when supply begins if the customer expressly consented, acknowledged being informed of the loss of that right and received confirmation. This is addressed through checkout, rather than a sentence in the terms.
  3. Do we have to verify reviews on our online shop? You do not have to verify reviews: the duty is to provide information. If you display reviews, explain whether and how you ensure they come from real customers. If you do not verify them, say so. Truthfulness is the boundary: labelling reviews as verified without real checks, or publishing commissioned fake reviews, is an unfair commercial practice. The same principle applies in Slovakia and Czechia.
  4. How many days do we have to resolve a defect complaint, and what if we miss the deadline? For goods, the seller must repair or replace the item within a reasonable period not exceeding 30 days after the defect is reported. A longer period is permitted only for an objective reason beyond the seller's control. The same cap applies to the period stated in the defect acknowledgement and to remedying a service defect. If the deadline expires without a remedy, the buyer may seek a proportionate price reduction or withdraw from the contract. The supervisory authority may penalise handling failures regardless of whether the defect actually existed.

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Mgr. Patrik Tulinský, LL.M. Czech and Slovak attorney · SAK 300422 · ČAK 19654

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