EU lawmakers are reportedly considering a delay in the enforcement of certain provisions of the EU Artificial Intelligence Act (AI Act). While the AI Act formally entered into force on 1 August 2024, its obligations apply on a rolling basis. Requirements related to AI literacy and the prohibition of specific AI practices have been applicable since 2 February 2025. Additional obligations are scheduled to come into effect on 2 August 2025 (general-purpose AI (GPAI) model obligations), 2 August 2026 (transparency obligations and obligations on Annex III high-risk AI systems), and 2 August 2027 (obligations on Annex I high-risk AI systems). The timeline and certainty of regulatory enforcement of these future obligations now appears uncertain.

The AI Act is not the only AI measure facing a delay. The publication of a code of practice for GPAI models—originally expected by 2 May 2025 under Article 56(9) of the AI Act—has been delayed, following concerns about drafts of the code expressed by a range of stakeholders. In addition, the technical standards intended to support regulated actors in demonstrating compliance with the AI Act have yet to be published. Against this backdrop, Poland, in its role holding the rotating Presidency of the Council of the EU, has reportedly proposed delaying the dates of application of the AI Act. 

No formal delay has been announced at the time of writing and the method of executing any such delay is not yet known. That said, based on recent precedent, the Commission could adopt a simple directive or regulation that effectively stops the clock. In 2024, for example, the EU adopted a regulation amending the Deforestation Regulation (Regulation (EU) 2023/1115) to delay its application by one year. And in 2025, the EU adopted a directive delaying certain aspects of the Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) and the Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760). The latter was proposed by the Commission and adopted and published in under seven weeks—one of the fastest EU legislative procedures ever. If the EU wants to delay GPAI model obligations prospectively, it will need to act fast. 2 August 2025—the date that the obligations on GPAI models begin to apply— is fast approaching. The last European Parliament plenary before the summer break—at which the Parliament would need to adopt its position—is the week of 7 July 2025. The Council and Parliament would need to complete negotiations before 10 July for the Parliament to approve the deal in Plenary before the summer break. Although not impossible, it would require clear political will to push this through.

This blog was drafted with the assistance of Dumitha Gunawardene, a trainee in the London office.

Photo of Lisa Peets Lisa Peets

Lisa Peets is co-chair of the firm’s Technology and Communications Regulation Practice Group and a member of the firm’s global Management Committee. Lisa divides her time between London and Brussels, and her practice encompasses regulatory compliance and investigations alongside legislative advocacy. For more…

Lisa Peets is co-chair of the firm’s Technology and Communications Regulation Practice Group and a member of the firm’s global Management Committee. Lisa divides her time between London and Brussels, and her practice encompasses regulatory compliance and investigations alongside legislative advocacy. For more than two decades, she has worked closely with many of the world’s best-known technology companies.

Lisa counsels clients on a range of EU and UK legal frameworks affecting technology providers, including data protection, content moderation, artificial intelligence, platform regulation, copyright, e-commerce and consumer protection, and the rapidly expanding universe of additional rules applicable to technology, data and online services.

Lisa also supports Covington’s disputes team in litigation involving technology providers.

According to Chambers UK (2024 edition), “Lisa provides an excellent service and familiarity with client needs.”

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Photo of Atli Stannard Atli Stannard

Atli Stannard is special counsel in the firm’s Public Policy practice. He guides clients in highly regulated industries through complex EU policymaking processes, protecting and advancing their core business and regulatory priorities.

Atli’s practice covers all aspects of EU policymaking and legislative advocacy…

Atli Stannard is special counsel in the firm’s Public Policy practice. He guides clients in highly regulated industries through complex EU policymaking processes, protecting and advancing their core business and regulatory priorities.

Atli’s practice covers all aspects of EU policymaking and legislative advocacy, including the regulation of the tech, food and beverage, pharmaceutical and medical devices, and industrial sectors, and on EU trade, environmental and ESG, and competition policy. He has handled matters before the European Commission, European Parliament, Council of the EU, and Member State and UK governments. Clients rely on him to identify regulatory risks and opportunities, and engage in the policy process to defend and promote their business interests. 

Technology: Atli has worked extensively for clients on matters relating to EU data, content, platform, Artificial Intelligence, and competition policy.
Food and beverage: Atli helps clients developing novel plant-based foods to secure the necessary regulatory authorizations and engage in broader EU food policymaking. He regularly engages with EU and national authorities to ensure that health and environmental regulations are based in rigorous scientific evidence. He has drawn on his trade policy expertise to assist clients seeking to import food products into the EU.
Drug & medical devices: Atli has counseled clients and engaged with the EU institutions on matters relating to genomics, the regulation of medical devices and in vitro diagnostics, health technology assessment, orphan medicines, and pricing.
Industrial: Atli helps clients engage with EU and national bodies on the environmental benefits of their innovative technologies, and on EU plastics, chemical, and product regulation.

In his EU trade policy work, Atli regularly advises clients facing on EU market access and customs classification issues, trade defense actions (tariffs and safeguard measures), and non-tariff barriers (including sanitary and phytosanitary measures). He helps clients engage in the EU’s negotiation of new trade agreements. He counsels clients on the impact of the upcoming Carbon Border Adjustment Mechanism, and how to shape and comply with its requirements.

Atli is a member of the firm’s ESG and Business and Human Rights Practices, and works with clients to assess the impact of and engage with new and upcoming Environmental, Social and Governance rules, including the EU Green Deal, supply chain diligence and the EU’s developing sustainable finance rules.

Atli’s competition policy advocacy work encompasses mergers, challenges under Articles 101 (anticompetitive agreements) and 102 (abuse of dominance) TFEU, and referrals under Article 22 of the EU Merger Regulation.

Atli has counseled international investors extensively on the EU’s proposals for a regime on foreign subsidies, and on the EU’s new FDI screening rules and coordination mechanism, as well as on EU tax policymaking. He also works closely with litigation colleagues to protect clients’ legitimate interests in multiple venues.

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Photo of Madelaine Harrington Madelaine Harrington

Madelaine Harrington is an associate in the technology and media group. Her practice covers a wide range of regulatory and policy matters at the cross-section of privacy, content moderation, artificial intelligence, and free expression. Madelaine has deep experience with regulatory investigations, and has…

Madelaine Harrington is an associate in the technology and media group. Her practice covers a wide range of regulatory and policy matters at the cross-section of privacy, content moderation, artificial intelligence, and free expression. Madelaine has deep experience with regulatory investigations, and has counseled multi-national companies on complex cross-jurisdictional fact-gathering exercises and responses to alleged non-compliance. She routinely counsels clients on compliance within the EU regulatory framework, including the General Data Protection Regulation (GDPR), among other EU laws and legislative proposals.

Madelaine’s representative matters include:

coordinating responses to investigations into the handling of personal information under the GDPR,
counseling major technology companies on the use of artificial intelligence, specifically facial recognition technology in public spaces,
advising a major technology company on the legality of hacking defense tactics,
advising a content company on compliance obligations under the DSA, including rules regarding recommender systems.

Madelaine’s work has previously involved representing U.S.-based clients on a wide range of First Amendment issues, including defamation lawsuits, access to courts, and FOIA. She maintains an active pro-bono practice representing journalists with various news-gathering needs.

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