Updated 17 October 2026. This article has been revised to separate the policy timeline from the product argument. See the current AI Act timeline for the category-specific dates and primary reference.
A transition period is a period with work to manage, not an empty space between two dates. Teams need to know which assumptions are temporary and what will replace them.
Keep a transition register
Record the affected system, the current position and the intended future state. Include the official source for the transition and the interpretation being used. A broad reference to “the AI Act delay” is not enough to explain a system-specific decision.
An illustrative entry might identify a documentation update that depends on a particular assessment. It should state what evidence exists now, what remains missing and who is responsible for completing it. That makes the gap visible without pretending that every missing item has the same significance.
Tie the register to actual changes in the product. If a system gains a new purpose or permission, review whether the old transition assessment still applies. A familiar product name does not guarantee an unchanged use case.
Use the register during release reviews, not only during annual reporting. Otherwise it can become a historical record of assumptions nobody remembers making. A deadline field is useful only when somebody acts on it.
| Decision | Evidence to request |
|---|---|
| Current state | Evidence and interpretation today |
| Future state | Required change and dependency |
| Review | Owner, trigger and updated decision |
What to do with this
The transition ends with a verified change in the system or its assessment. It should not end with somebody changing the colour of a cell and hoping the evidence follows.
Record the decision, the responsible owner and the evidence still missing. The decision-record example shows a lightweight way to do that. Where a claim concerns system behaviour, connect it to evaluation evidence. These are proposed product practices, not a finding that a system complies with the law.
Primary timeline reference: European Commission, AI Act. The operational recommendations above are my analysis.
