Keeping Pace with the AI Act: A Snapshot of Recent Developments
The EU AI Act continued to move rapidly from law on paper to law in practice in recent weeks, with significant developments at both European and national level. This briefing summarises the key milestones.
AI Simplification
On 16 June 2026, the European Parliament approved amendments to the EU AI Act as part of a digital omnibus package, aiming to simplify compliance while preserving its core risk-based approach. The Council of the EU approved the measures on 29 June 2026. Key changes include postponed timelines for certain high-risk AI obligations: rules for stand-alone high-risk systems apply from 2 December 2027, and those embedded in safety-regulated products from 2 August 2028. Watermarking requirements are postponed until 2 December 2026. There is an outright ban on AI tools that generate non-consensual sexually explicit content or child sexual abuse material, with compliance required by 2 December 2026. Overlaps with machinery safety laws are removed, limited processing of special category personal data is permitted with safeguards, certain exemptions are extended to small mid-cap enterprises, and general-purpose AI enforcement is centralised in the EU's AI Office.
Ireland’s Regulation of Artificial Intelligence Bill 2026
On 17 June 2026, the Irish Government approved the publication of the Regulation of Artificial Intelligence Bill 2026, which is intended to implement and support enforcement of the EU AI Act in Ireland. The bill completed Second Stage in the Dáil on 24 June 2026, and the Committee and Remaining Stages on 30 June 2026. The bill completed the Seanad Second Stage on 1 July 2026, and is currently in the Seanad Committee Stage.
Classification of High-Risk AI Systems
On 19 May 2026, the European Commission published a targeted consultation on draft guidelines for the classification of high-risk AI systems, which will run until 23 July 2026. The guidelines will aim to support AI providers and deployers in assessing whether their system is high-risk or not. A limited set of AI use cases are considered as high-risk under the EU AI Act where they endanger health, safety or fundamental rights. The draft guidelines provide detailed guidance on how to determine whether an AI system falls within the high-risk categories, with significant implications across sectors including employment, essential services, and critical infrastructure.
In a series of briefings on the draft guidelines, we looked at what employers, critical infrastructure operators and essential services providers need to know.
Transparency under Article 50
The European Commission opened a consultation on draft guidelines for the EU AI Act’s Article 50 transparency obligations for providers and deployers of generative AI systems on 8 May 2026, which closed on 3 June 2026. The Commission will now work on finalising the guidelines.
On 10 June 2026, the European Commission published the final Code of Practice on Transparency of AI-Generated Content. The Code of Practice aims to help providers and deployers of generative AI comply with the Article 50 transparency requirements of the EU AI Act. The Code outlines practical measures such as clearly labelling deepfakes and AI-generated or manipulated content on matters of public interest. This will inform users when they interact with AI systems like chatbots and ensure AI-generated content can be machine-detectable. The Code is open for organisations to sign.
The Article 50 obligations (with the exception of the watermarking obligations on AI-generated content which are due to take effect on 2 December 2026), will become applicable on 2 August 2026.
Read our recent briefings relating to transparency under Article 50 here and here.
Enforcement Bodies Appointed
On 1 June 2026, the European Commission announced the appointment of a Scientific Panel and an Advisory Forum to support EU AI Act enforcement. The Scientific Panel comprises 60 independent experts focused on general-purpose AI systems, systemic risks, and cross-border oversight, while the Advisory Forum addresses standardisation and implementation challenges.
First EU Annual Report on the EU AI Act
On 22 May 2026, the European Commission published its first annual report on the need to review the list of prohibited AI practices and of high-risk AI systems. The report concludes that it is too early to amend the EU AI Act’s rules on prohibited practices and high‑risk use cases, given its recent entry into force and limited enforcement experience to-date. While no immediate changes are proposed, the report highlights emerging risks including in relation to non‑consensual nude and sexually explicit deepfakes, as well as concerns regarding emotion recognition technologies, self-help AI chatbots, scams and political disinformation campaigns.
How Can McCann FitzGerald Help?
For further information or assistance, please reach out to one of the key contacts below, or your usual contact at McCann FitzGerald LLP.
This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.
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