The 2 August 2026 compliance trap: why the EU AI Act already affects your daily business

In recent weeks the headlines went through the business press: with the so-called “Digital Omnibus”, the EU is pushing strict AI rules back, and high-risk systems get a reprieve until December 2027. The reaction in the mid-market is understandable – but risky: “So we still have time, we can put the topic off until next year.”

This is exactly where the error lies. Thomas Fischer, AI expert at PASSION4IT, has been watching the developments for months and warns: the postponement affects only part of the EU AI Act. The obligations for completely ordinary, everyday AI use – that is, what your teams have long been doing with ChatGPT, Copilot or Midjourney – go live on 2 August 2026.

“Many managing directors are lulling themselves into a false sense of security right now. Anyone who sits out the baseline obligations until autumn risks not just warnings, but substantial fines.” — Thomas Fischer, AI expert at PASSION4IT

The EU AI Act is therefore no longer an abstract Brussels construct that only concerns tech giants. It explicitly puts the users of AI under obligation, too. Three points belong on every management team’s radar now.

1. AI literacy obligation (Art. 4) – already in force

This obligation has been in force since February 2025 and was not postponed by the Omnibus. Anyone using AI in sales, marketing or service must be able to demonstrate that their staff have “sufficient AI competence”. Without documented training, attendance lists and internal guidelines, you are left empty-handed in the event of a dispute.

2. Transparency obligation (Art. 50) – from 2 August 2026

AI-generated content must be clearly labelled as such. Service chatbots, AI texts in marketing, voice clones: it must be recognisable to users that they are interacting with a machine. For existing systems there is a technical grace period until December 2026 (for example for watermarks in images), but the fundamental disclosure obligation already applies in August.

3. Supply-chain obligation (Art. 23 & 24) – from 2 August 2026

Anyone who imports AI tools or passes them on becomes part of the AI supply chain and needs contractual assurances from their software vendors that their models meet the European requirements.

The good news: you don’t have to manage this alone

From our consulting practice at PASSION4IT we see it every day: most companies don’t underestimate the technology, but the burden of proof. AI has long been in use – but hardly anyone can document who was trained, which rules apply and how content is labelled. This is exactly where we step in. For each of the three obligations, we have the right answer.

For the literacy obligation: the AI driver’s licence from our Academy. With the AI driver’s licence we bring your teams up to the required competence level in a hands-on way – and issue a certificate that gives you proof under Art. 4 in black and white. That way you don’t just meet the obligation, you can demonstrate it at any time. Exactly what counts in a dispute.

For the transparency and supply-chain obligations: our AI consulting. Together with you we draw up a legally sound AI usage policy, clarify labelling obligations and check your AI supply chain for gaps. And the best part: this consulting can be subsidised through the BAFA funding programme – but only until the end of 2026. Here, too, acting quickly pays off twice over.

For the overview: the AI readiness check. Don’t know where your company stands? Our AI readiness check shows you in just a few minutes which of the three obligations you already meet – and where gaps remain before August.

The 2nd of August 2026 is closer than it sounds. Those who start now have their training documented, their policies in place and their funding secured before things get tight.

Take the first step: start the AI readiness check now – free of charge and in just a few minutes. Or book a call with our team directly.

This article is for information purposes and does not constitute legal advice.