The December 2026 AI Act dates: what actually lands this winter
Two things happen in December 2026: the generative-AI marking transition ends, and Ireland's AI Office gets its full powers. Neither is what most headlines say.
2 December 2026: the marking transition ends
Providers of generative AI systems that were on the market before 2 August 2026 have until 2 December 2026 to implement machine-readable marking of outputs (Article 50(2)). After that date, the distinction between older and newer systems disappears for this duty.
This is narrower than 'the AI Act starts in December'. Everything else in Article 50, and all of Article 4, has been enforceable since August.
December 2026 in Ireland: enforcement gets teeth
The AI Office of Ireland's full compulsory information-gathering powers commence in December 2026. From then, Irish businesses can receive formal information requests about their AI use, and 'we have nothing written down' is a bad answer.
The winter to-do list
If you provide a generative AI product: ship machine-readable marking before 2 December. Every other business: have your inventory, literacy evidence, and disclosures in order before information requests start landing. Both are days of work now, and much more under regulatory pressure.
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Run the scope checkCompliance information, not legal advice. Basis: Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, directly applicable in all EU member states; national implementing laws vary by country. Last reviewed 23 August 2026.