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Connecticut CART Act first obligations begin · Oct 1, 2026 · See what changes
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The world's first comprehensive AI law, classifying AI systems by risk level and imposing obligations that scale with risk. High-risk AI systems must undergo conformity assessment, maintain documentation, and implement human oversight. Under Regulation (EU) 2026/1744, obligations for Annex III high-risk systems now apply from December 2, 2027, moved back from August 2, 2026.
If you sell AI products to EU customers or deploy AI in the EU, you need to determine your risk classification now. Most SaaS tools fall in the limited-risk category, requiring only transparency disclosures. If your AI is used in hiring, credit, education, or critical infrastructure, you are in the high-risk category and face substantial compliance obligations, now due by December 2, 2027 rather than August 2, 2026.
Up to €35M or 7% of global annual turnover for prohibited AI violations; €15M or 3% for other violations
Italy's data protection authority temporarily banned ChatGPT from processing Italian users' data, citing GDPR violations: no lawful basis for mass collection of training data, no age verification to prevent minors from accessing the service, and failure to provide adequate transparency about data collection. OpenAI had 20 days to comply or face a permanent ban.
Outcome: ChatGPT was blocked for Italian users for approximately one month (March 31 – April 28, 2023). OpenAI resolved the ban by implementing an age verification mechanism, adding a GDPR privacy notice, and providing an opt-out mechanism for Italian users' data. The Garante later opened a separate formal investigation.
The newly established EU AI Office launched its first formal inquiry into GPAI model providers under Article 51 of the EU AI Act. The probe examines whether frontier model providers are complying with the Act's transparency and documentation requirements for general-purpose AI models, including copyright compliance summaries and technical documentation. This marks the first enforcement action under the EU AI Act and signals how the AI Office will interpret provider obligations.
Outcome: Ongoing investigation as of Q1 2026. No penalties imposed yet. The inquiry signals that the EU AI Office is actively monitoring GPAI model providers and is prepared to use its Article 101 powers (fines up to 3% of global turnover) for non-compliance with GPAI obligations.