Art. 111 AI systems already placed on the market or put into service and general-purpose AI models already placed on the marked | AI act regulation | AI act

This is a transitional provisions article, setting out the compliance deadlines for AI systems and models that were already on the market or in service before the Regulation's main application date.

It works in conjunction with the general application timeline established in Article 113, carving out extended deadlines for different categories of existing systems.

Rather than requiring immediate compliance, it gives operators, providers, and deployers a graduated runway to bring legacy systems into line with the new rules.

Important points:

AI systems embedded in large-scale IT systems listed in Annex X and already in service before 2 August 2027 must be brought into compliance by 31 December 2030.
Operators of high-risk AI systems already on the market before 2 August 2026 are only caught by the Regulation if those systems undergo significant design changes — however, providers and deployers of high-risk AI systems intended for use by public authorities must comply by 2 August 2030 regardless.
Providers of general-purpose AI models already on the market before 2 August 2025 must comply with their obligations under the Regulation by 2 August 2027.

1. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), AI systems which are components of the large-scale IT systems established by the legal acts listed in Annex X that have been placed on the market or put into service before 2 August 2027 shall be brought into compliance with this Regulation by 31 December 2030.
2. The requirements laid down in this Regulation shall be taken into account in the evaluation of each large-scale IT system established by the legal acts listed in Annex X to be undertaken as provided for in those legal acts and where those legal acts are replaced or amended.
1. Without prejudice to the application of Article 5 as referred to in Article 113(3), point (a), this Regulation shall apply to operators of high-risk AI systems, other than the systems referred to in paragraph 1 of this Article, that have been placed on the market or put into service before 2 August 2026, only if, as from that date, those systems are subject to significant changes in their designs. In any case, the providers and deployers of high-risk AI systems intended to be used by public authorities shall take the necessary steps to comply with the requirements and obligations of this Regulation by 2 August 2030.
1. Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027.

Article 111 AI systems already placed on the market or put into service and general-purpose AI models already placed on the marked

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