Upcoming Deadlines

Two major Chinese AI regulations effective July 15: (1) Interim Measures for the Administration of AI Anthropomorphic Interactive Services (issued April 10, 2026 by CAC/NDRC/MIIT/MPS/SAMR) - requires algorithm filing and CAC security assessment for AI companion and emotionally interactive services; bans virtual companion services for minors; mandates disclosure that service is AI not human. (2) Implementation Opinions on the Standardized Application and Innovative Development of Intelligent Agents (issued May 8, 2026 by CAC/NDRC/MIIT) - first national framework for agentic AI as a distinct regulatory category; mandatory filing and compliance testing for AI agents in healthcare, transportation, media, and public safety.

Companies within the scope of Article 50 of the EU AI Act (chatbot disclosure, AI-generated content marking, deepfake labelling) that sign the EU AI Office's Code of Practice on Transparency of AI-Generated Content by July 22 receive a presumption of conformity with Article 50 obligations when they become binding August 2. Non-signatories face heightened regulatory scrutiny. Missing the July 22 deadline does not bar later signing, but signatories after July 22 do not receive initial-signatory status.

Public comment period closes July 31, 2026 on the FTC's proposed policy statement asserting that AI companies secretly steering outputs toward undisclosed ideological objectives may violate Section 5 of the FTC Act. Comments at regulations.gov, Matter No. P264200. The proposed statement was issued pursuant to EO 14365 (December 11, 2025), which directed the FTC to clarify Section 5 as it applies to AI and to address how state laws requiring output alterations might conflict with federal law.

The voluntary pre-release engagement framework for covered frontier models under EO 14409 is to be finalized around August 1, 2026. Agencies also develop classified benchmarks to identify which models warrant the covered-frontier-model designation.

The EU Digital Omnibus received Council final approval June 29, 2026. Official Journal publication expected any day (must precede August 2). The high-risk AI deferral to December 2, 2027 takes legal effect 3 days after OJ publication - NOT before. Until published, companies cannot formally rely on the new dates. GPAI and Article 50 deadlines on August 2 are NOT affected by the Omnibus.

The Commission gains active enforcement powers over general-purpose AI providers, and Article 50 transparency (marking and labelling of AI-generated content, chatbot disclosure, deepfake labelling) becomes binding. These deadlines were NOT delayed by the Digital Omnibus. Final Code of Practice published June 10, 2026.

Missouri's prohibition on advertising or claiming AI can act as a mental health professional, provide therapy, or offer mental health diagnosis takes effect August 28, 2026. Enforcement through the Missouri Attorney General under the Missouri Merchandising Practices Act. First offense $10,000; subsequent violations $20,000. Missouri joins Tennessee (July 1), Vermont (June 17), and Rhode Island (June 22) in the bipartisan wave of state therapy-chatbot restrictions.

Connecticut Public Act 26-15 (AI Responsibility and Transparency Act / CART Act) begins its phased rollout on October 1, 2026. Initial obligations include employer notice when AI tools are used in employment-related decisions, transparency about AI-related reductions in force, and the clarification that using AI is not a defense to antidiscrimination claims. Additional provisions take effect October 1, 2027.

Following the ESRB July 7 warning on systemic cyber risks from frontier AI models, the ECB set an October 31, 2026 deadline for significant eurozone banks to submit AI cybersecurity action plans addressing AI-enhanced cyber threats to financial stability.

New York S6953-B (RAISE Act) takes effect for frontier AI model developers with over $500M annual revenue. Requires safety protocols, AI impact assessments, 72-hour incident reporting to new NY AI oversight office. Penalties up to $1M first violation, $3M subsequent.

Illinois SB 315 (Artificial Intelligence Safety Measures Act), signed by Governor Pritzker on July 6, 2026, takes effect January 1, 2027. Requires AI model developers with over $500 million in annual revenue to: publish a catastrophic risk framework; undergo annual independent third-party audits (first-in-nation requirement); report incidents within 72 hours (24 hours if imminent death/injury risk); and extend whistleblower protections. Effective the same day as Colorado SB 26-189, NY RAISE Act, creating a multi-state frontier AI compliance event.

Colorado SB 26-189 (automated decision-making technology notice-and-explanation framework) takes effect. Replaces SB 24-205's higher-risk AI compliance regime with a narrower ADMT disclosure requirement, exclusive AG enforcement.

Stand-alone Annex III high-risk AI obligations, originally due August 2, 2026, were delayed to December 2, 2027 under the Digital Omnibus (Parliament approved June 16, 2026; formal adoption pending before August 2, 2026). Annex I embedded-product high-risk systems move to August 2, 2028. GPAI transparency in force since August 2, 2025. Penalties up to 7% global annual turnover.

High-risk obligations for AI embedded in regulated products under Annex I, deferred to August 2, 2028 under the Digital Omnibus (from the original August 2, 2027 timeline). Represents full implementation of high-risk EU AI Act requirements for product-embedded systems.