The European Union's AI Act has been law since 2024, but its duties arrive in stages rather than all at once. The next stage lands on 2 August 2026. From that date the remaining provisions apply and the European Commission gains the power to enforce the rules on general-purpose AI models and to impose fines. A UK firm sits outside the EU, so the first question is whether any of this reaches you. For most firms the honest answer is that parts of it can, and the rest shapes the tools you buy.
What changes on 2 August 2026
The obligations on general-purpose AI models, the large systems that sit behind ChatGPT, Gemini, Copilot, Claude, Llama and Mistral, took effect a year earlier, on 2 August 2025. What switches on now is enforcement. From August the Commission can act against a model provider that fails to meet those obligations, with fines reaching fifteen million euros or three percent of worldwide annual turnover, whichever is higher. The duties themselves are matters of paperwork and disclosure. A provider has to keep technical documentation, publish instructions for use, put out a summary of the data used in training, and comply with EU copyright rules.
What the Digital Omnibus moved, and what it left
In May 2026 the EU agreed a package known as the Digital Omnibus to simplify parts of the Act. It pushed the heaviest obligations, those on high-risk systems in areas such as employment, education and border control, back from August 2026 to December 2027, with systems built into regulated products following in 2028. That deferral does not touch the two duties that arrive now. The general-purpose AI enforcement date held firm, and so did the transparency obligations in Article 50. Read against the headlines about delay, the relief is narrower than it first appears.
Where the transparency rules reach a UK firm
Article 50 is the part most relevant to a working firm. It requires anyone deploying certain AI systems to be open about it, to tell a person when they are dealing with a machine rather than a human, and to label content that has been generated or altered by AI. The Act reaches providers and deployers based outside the EU where the output of the system is used within the Union. A firm advising a client based in an EU member state, or running a client-facing chatbot reachable from Europe, should treat these duties as live. The practical steps are small. Say plainly where a person is speaking to an AI tool, and mark AI-generated material as such. This sits close to what the SRA already expects when it asks you to make clear where a client meets AI, covered in what the rules require of you.
The tools you buy carry more with them
Even where the Act does not bind your firm directly, it changes what your suppliers must hand over. Model providers now have to publish documentation, usage instructions and a summary of their training data. That is the material a firm needs when it weighs a tool against its own duties under the SRA and UK GDPR. When you next assess a legal AI product, ask the vendor for its AI Act documentation and read what it says about intended use and limits. A supplier that cannot produce it is telling you something. We set out the wider approach in choosing legal AI tools for the small firm.
What a firm should do
Start by working out whether any of your AI use touches the EU, through clients, offices or public-facing tools. If it does, add a short line of disclosure wherever a person meets an AI system, and label synthetic content. Whether or not the Act binds you, use the new vendor documentation to sharpen your own due diligence under UK data protection law, set out in UK GDPR when client data meets AI. Keep a note of what you relied on. None of this asks a small firm to become an expert in European regulation. It asks you to know where your tools sit, tell people the truth about them, and record your reasoning.
The Act itself is on EUR-Lex for anyone who wants the source text rather than a summary.
If EU clients or EU matters touch your practice, ten minutes with us tells you whether the Act reaches you and what to do about it: start with a conversation.