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AI Regulation Deadline Tracker

Selected EU and US AI obligations with a primary source and review date for each entry. Review cadence: monthly. Date labels advance automatically; source-review dates change only after an editorial review.

Jurisdiction

Status

12 obligations

5 Jul 2023

Date reachedNew York City

Annual independent bias audit for automated employment tools

Local Law 144

Who it lands on
Employers and employment agencies using automated tools in hiring or promotion decisions in New York City.
What it requires
An annual bias audit by an independent auditor, published summary of results, and candidate notice.
Exposure
$500-1,500 per day, per violation.

5 July 2023 is the enforcement start date. Covered tools require an independent audit within one year of use, public audit information and notices at least ten business days before use.

NYC Department of Consumer and Worker Protection · Reviewed 22 Sep 2026

1 Jan 2026

Date reachedTexas

Texas Responsible AI Governance Act in force

TRAIGA (HB 149)

Who it lands on
Government agencies, healthcare providers and their vendors, and anyone deploying AI toward Texas consumers.
What it requires
AI interaction disclosure for government entities and healthcare providers in specified circumstances; prohibited-use rules have a wider scope.
Exposure
Curable violations $10-12K each; uncurable $80-200K; continuing violations $2-40K per day.

Defences and cure provisions have conditions. Framework alignment alone should not be treated as blanket immunity; review the enacted provisions for the actual use.

Texas Legislature — HB 149 · Reviewed 22 Sep 2026

1 Jan 2026

Date reachedCalifornia

Frontier model transparency and safety reporting

SB 53 (TFAIA)

Who it lands on
Frontier developers above the compute threshold, with the heavier obligations attaching above a large revenue threshold.
What it requires
Published safety framework, incident reporting, and transparency reporting.

Scope depends on the statutory frontier-model and developer definitions. The safety-framework duty and incident-reporting duty do not have identical thresholds.

California Legislative Information — SB 53 · Reviewed 22 Sep 2026

14 May 2026

RepealedColorado

Prior Colorado AI Act repealed before it ever took effect

SB 24-205, repealed by SB 26-189

Who it lands on
Teams that built compliance programs against SB 24-205's high-risk framework.
What it requires
Nothing, as of the repeal date. The duty-of-care standard, annual impact assessments, and risk-management programs were all eliminated with the statute that required them. What survives is the narrower notice, explanation, and human-review regime in the row above.

Kept on this list deliberately: a repealed law is easy to keep preparing for by accident. Work already done against the old framework is not wasted — inventory and data-flow mapping carry straight over — but impact-assessment templates can be retired.

Colorado General Assembly — SB 26-189 (replacement) · Reviewed 22 Sep 2026

2 Aug 2026

Date reachedEU

Transparency obligations applicable

EU AI Act, Article 50 — Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744

Who it lands on
Providers and deployers of systems that interact with people or generate synthetic content, selling into the EU.
What it requires
Disclosure at the interaction boundary, marking of synthetic content in a machine-readable form, and records that show both are actually happening.

The transparency duties themselves were left untouched by the AI Omnibus; the only change was the marking grace period below.

EUR-Lex — EU AI Act (Regulation 2024/1689) · Reviewed 22 Sep 2026

1 Sep 2026

Date reachedTexas

Attorney General complaint portal required

TRAIGA (HB 149)

Who it lands on
Everyone in scope of TRAIGA, indirectly.
What it requires
This is a deadline for the Attorney General to provide a complaint channel, not a direct engineering duty on a business. The date alone does not verify that the portal is operational.
Texas Legislature — HB 149 · Reviewed 22 Sep 2026

2 Dec 2026

UpcomingEU

Content-marking grace period ends for legacy systems

Regulation (EU) 2026/1744 — the AI Omnibus, amending the transitional provisions for Article 50(2)

Who it lands on
Systems already in service before the transparency obligations became applicable.
What it requires
The marking mechanics that new systems already needed, retrofitted onto the deployed estate. This is the one that is usually underestimated: retrofitting provenance into an existing generation path is engineering work, not a policy update.

Adopted 8 July 2026 and in force since 27 July 2026. The transition covers only the Article 50(2) marking duty for qualifying pre-August systems; it does not postpone the other transparency duties.

EUR-Lex — Regulation (EU) 2026/1744 · Reviewed 22 Sep 2026

1 Jan 2027

UpcomingColorado

Colorado AI Act replacement takes effect

SB 26-189

Who it lands on
Deployers of systems making consequential decisions about Colorado residents.
What it requires
Pre-use notice, notice within 30 days of an adverse decision, a human review path, and three years of records.
Exposure
Up to $20K per violation.

Review the enacted definitions, exceptions and cure provisions for the specific workflow. The effective date is separate from any enforcement action.

Colorado General Assembly — SB 26-189 · Reviewed 22 Sep 2026

2 Dec 2027

UpcomingEU

High-risk obligations apply to Annex III systems

EU AI Act, Annex III

Who it lands on
Systems in the listed high-risk categories: employment, credit, essential services, education, and the rest of the Annex III list.
What it requires
Risk management, data governance, technical documentation, logging, human oversight, accuracy and robustness measures, and conformity assessment.

This date moved once already. It is the deadline most people plan around and the one least safe to treat as fixed — in either direction.

EUR-Lex — EU AI Act · Reviewed 22 Sep 2026

2 Aug 2028

UpcomingEU

High-risk obligations apply to Annex I systems

EU AI Act, Annex I

Who it lands on
AI embedded in products already covered by EU product-safety legislation.
What it requires
The high-risk regime, routed through the existing sectoral conformity assessment rather than a standalone one.
EUR-Lex — EU AI Act · Reviewed 22 Sep 2026

Insurance renewals follow your own policy dates. Ask your broker what evidence is required; there is no universal renewal deadline.

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How this works, and what it does not cover

This list covers obligations that reach a team building or deploying AI products. It does not cover sector-specific supervision, employment law generally, or anything that applies to you only because of what industry you are in.

Every row names the instrument and links to primary source — EUR-Lex, the state legislature, or the agency. Secondary commentary is not treated as a source. Where enforcement is paused, litigated, or merely expected, the row says so rather than implying certainty that does not exist.

European AI policy has already moved one of these dates once, and state legislatures move faster than that. If you are making a decision with money attached, open the source link.

This is a technical reading of what each obligation requires in engineering terms. It is not legal advice — for applicability questions, counsel has the final word, and the primary-source links are there to make those conversations faster.

Verified against source on September 22, 2026.

An email when a date on this list moves, and nothing else. European AI policy is volatile by design; the tracker gets corrected when it changes.

Request by email

n@nickcerutti.com · Include the question or project you have in mind.

If you would rather not do this yourself

AI Compliance Package — EU Article 50 plus US module

Three weeks: the transparency and marking controls the regulation asks for, running in production, plus the optional US state module.

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