Potentially, if the product or its use falls within the Act’s territorial scope. Determine whether the company is acting as provider, deployer, importer or another relevant actor, and whether adaptation changes that role.
The Commission’s updated implementation timeline incorporates the Digital Omnibus: transparency rules apply from 2 August 2026, Annex III high-risk rules are listed for 2 December 2027, and high-risk systems in regulated products for 2 August 2028. There are transitional provisions and other milestones. Do not present the old “all high-risk rules start August 2026” line as current.
For procurement, request the intended-use statement and identify which party produces documentation, handles incidents and communicates model changes. Ask counsel about territorial scope and classification rather than inserting a generic “AI Act compliant” warranty with no deliverables behind it.