The Three Timelines of the EU AI Act
Which one drives your audit risk - and why it’s not the one you think
Executive Summary
The EU AI Act now lives inside a broader, more complex regulatory universe. With the Digital Omnibus on the table and post-Omnibus commentary spreading like wildfire, leadership teams are once again recalculating when they “really” need to be compliant.
Some are locking onto the political cycle: Council conclusions, Omnibus negotiations, and Commission communications that suggest gradual simplification.
Others fixate on enforcement: stop-the-clock mechanisms, extended grace periods, and the apparent shift of high-risk penalties into late 2027.
Almost no one is looking at the only timeline that actually governs financial exposure: the date when classification and documentation obligations crystallize for every AI system they place on the EU market.
The EU AI Act is now operating across three distinct timelines:
A Political Timeline - volatile, headline-driven, and structurally incapable of telling you when your risk actually starts.
An Enforcement Timeline - flexible, dependent on national capacity and Commission acceleration choices, and frequently misread as “extra time.”
A Classification Timeline - fixed, anchored in August 2026, and tied not to enforcement but to the act of placing systems on the market and registering high-risk determinations.
Most organizations are optimizing for the first two. Their decisions are rational from a distance, but structurally misaligned with how the Act actually creates exposure.
This piece does three things:
It explains how these three timelines emerged and why they are diverging after the Digital Omnibus.
It shows why only the classification timeline is a reliable anchor for financial risk — and why it did not move.
It outlines how leadership teams should structure their 2025-2026 roadmap if they want to use Omnibus “simplification” as a competitive advantage rather than a justification for delay.
The conclusion is blunt: political and enforcement timelines can move; the classification timeline cannot. If your organization is still waiting for “clarity” before it starts classification, you are betting your balance sheet on the wrong clock.