Today is August 14, 2025. The EU AI Act‘s high-risk system deadline is August 2, 2026.
That’s 352 days.
If you’re a provider or deployer of high-risk AI systems in Europe, this timeline should already have your full attention. Here’s why: the path to compliance isn’t a sprint you can start in Q2 2026. It’s a marathon that should have started yesterday.
The Brutal Math of Compliance
- System Inventory & Gap Analysis: 4-8 weeks
Most companies don’t have a complete AI inventory today. You need to identify every AI system in production and development, classify risk levels (spoiler: you have more high-risk systems than you think), and map current versus required documentation. This isn’t a spreadsheet exercise—it’s forensic archaeology through your tech stack. - Technical Modifications: 12-20 weeks
Article 10 data governance requirements. Mandatory human oversight features. Audit trails and logging mechanisms. Bias detection and mitigation systems. These aren’t patches—they’re often architectural changes that touch core system design. Legacy systems built without compliance in mind? Add another 8 weeks. - Documentation Production: 8-12 weeks (parallel but dependent)
The AI Act’s documentation requirements are prescriptive and detailed. Technical documentation per Article 11. Instructions for use under Article 13. Risk management documentation. Quality management system documentation. This isn’t your standard technical documentation—it’s evidence of ongoing monitoring, continuous improvement, and systematic risk management. - Conformity Assessment: 8-16 weeks
Internal testing and validation. Notified body selection (for Annex III systems). Assessment scheduling—and here’s the kicker: notified bodies are already booking into Q2 2026. Then comes remediation of findings and the CE marking process. - Total realistic timeline: 32-56 weeks
That’s 8-14 months if everything goes perfectly.
The Bottlenecks Nobody’s Talking About
- Notified body capacity will be severely limited at launch. With most Member States unprepared and the system only going live August 2025, the scramble for assessment slots will be intense.
- Your AI vendors won’t save you. Deployers have independent obligations. If your vendor hasn’t started their compliance journey, you’re still on the hook.
- The technical debt is real. Systems built without compliance architecture need fundamental restructuring, not cosmetic changes.
- The expertise gap is critical. You need people who understand AI systems AND regulatory compliance. This talent pool is tiny, expensive, and already committed elsewhere.
How to Compress the Timeline
This is where modern AI governance platforms become essential. Modulos, for instance, uses AI agents to automate governance workflows and can integrate across MLOps, LLMOps, and auditing infrastructures. The Modulos AI Governance Platform can cut documentation time by up to 90% through intelligent automation.
Even with these tools, the timeline is tight. A platform like Modulos can apply single controls across multiple frameworks (EU AI Act, ISO 42001, NIST AI RMF), dramatically reducing duplication reducing duplication of work, documentation efforts, and oversight across teams. But automation doesn’t eliminate the need for technical modifications or assessment scheduling.
The real value? Parallel processing. While your engineers implement technical changes, automated governance platforms can handle documentation, risk assessment, and evidence collection simultaneously. This can compress that 32-56 week timeline to 24-40 weeks—still tight, but achievable.
The Reality Check
This timeline assumes:
- No major architectural rebuilds beyond planned modifications
- No failed assessments requiring complete remediation
- No vendor delays or dependency blocks
- No internal resource conflicts with other priorities
- Notified body availability when you need it
When did enterprise AI deployment ever go exactly to plan?
If you’re starting your compliance journey today, you’re not early. You’re on time—barely. Every week of delay now is a week you can’t recover in 2026. The companies that will successfully meet the August 2026 deadline aren’t the ones starting next year. They’re the ones mapping their systems today, selecting their governance tools this quarter, and beginning technical modifications before the year ends.
The clock isn’t just ticking. It’s racing.
Don’t wait until 2026 — start your EU AI Act high-risk compliance journey today.
Book a free consultation with our AI governance experts and see how Modulos can help you meet requirements on time.