AI legal status.
November 2026: what applies, what has changed and what comes next.
The status at a glance.#
Legal status: 5 November 2026.
| Regulation | Status | Since / from |
|---|---|---|
| AI Act: prohibitions and AI literacy (Art. 4) | applies | 2 February 2025 |
| General-purpose AI models | applies | 2 August 2025 |
| Transparency (Art. 50) and national supervision | applies (check individual transitional rules) | 2 August 2026 |
| High-risk AI under Annex III | postponed | 2 December 2027 |
| High-risk AI under Annex I (products) | postponed | 2 August 2028 |
| Digital Omnibus, Regulation (EU) 2026/1744 | in force | July 2026 |
| KI-MIG (Germany) | in force | 28 July 2026 |
| Product Liability Directive (EU) 2024/2853 | Transposition by the member states | by 9 December 2026 |
| Colorado SB 26-189 (USA) | planned, implementation open | 1 January 2027 |
What changed recently.#
Digital Omnibus
The high-risk obligations were postponed and new prohibitions were added.
KI-MIG
The Federal Network Agency has been the central market surveillance authority since 28 July 2026.
Transparency
Since August 2026, labelling and disclosure obligations under Art. 50 apply.
Archive.#
Every month I review the status and update this page.
The detailed version comparing the EU, Germany and the USA is on the AI regulation page. All changes are also listed under News.
Guidance without legal advice. Have important decisions checked legally.
Questions? Get in touch.
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Sources and further reading
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Suggested citation: Russo, K.: "AI legal status". sicherheitsdenker.de/en/ki-rechtsstand/, as of 6 November 2026.