AI law requirements for product teams (2026–2027)

What changed on the calendar

The EU AI Act (Regulation (EU) 2024/1689) is already in force. Article 113 makes most of the Act, including Chapter IV transparency obligations, applicable from 2 August 2026. The European Commission’s Article 50 guidelines confirm that date. Article 111(4), as amended, then gives providers of generative systems that were already placed on the market before 2 August 2026 until 2 December 2026 to meet the Article 50(2) machine-readable marking duty. Everything else in Article 50 applied on 2 August 2026.

California Civil Code § 3111 (AB 2013, chaptered 28 September 2024) required developers of in-scope generative systems released on or after 1 January 2022 to post training-data documentation on or before 1 January 2026, and again before each later substantial modification made available to Californians.

Colorado SB26-189, approved 14 May 2026, repealed and reenacted the 2024 Colorado AI Act (SB24-205). Section 5 of the new act takes effect 1 January 2027 and applies to consequential decisions made on or after that date.

Start with the law that matches the feature

Do not start with the whole AI Act. Start with the feature you already shipped.

• A chatbot or in-app copilot that talks to a person → Article 50(1) disclosure, then the chatbot pages.
• A product that emits images, audio, video, or long-form text → Article 50(2) marking and, if you publish the output, Article 50(4) labeling.
• A generative model you trained or substantially modified and offer to Californians → AB 2013 / § 3111 documentation.
• A tool that ranks, scores, or decides education, employment, housing, credit, insurance, health care, or essential government services for Coloradans → SB26-189 notices from 1 January 2027.

What scm.cc will do after you read this

The free AI Law Check is three questions about the feature, the users, and the output. It does not produce a readiness report. The paid readiness report is an engineering gap analysis: which disclosures, marks, dataset fields, and notices are missing from the product you described. Annual plans (Starter $49/mo, Growth $149/mo, Scale $399/mo) include two months free.

Questions teams ask

Is this legal advice?

No. Every page in this hub is educational product guidance. Confirm the official text — EUR-Lex, California Legislative Information, the Colorado General Assembly — before you ship.

Does Article 50 apply if we only have US customers?

Article 2 reaches providers and deployers outside the Union when the output of the AI system is used in the Union. A US-hosted chatbot that EU users can open is the usual in-scope case. Read the chatbot scope page before you decide you are out.

What happened to the original Colorado AI Act?

SB24-205 created Part 17 in 2024. SB26-189 repealed and reenacted that part. Do not implement the February 2026 SB24-205 dates; implement SB26-189 from 1 January 2027.

Related pages

• AI Act Article 50 transparency requirements
• California AB 2013 training-data transparency requirements
• Colorado SB26-189 requirements (the law that replaced the Colorado AI Act)
• Free AI-law templates: disclosure, labeling, AB 2013, Colorado notice

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