EU AI Act Art.110: Transitional Provisions for Union Institutions — AI Systems in EU Bodies Compliance Guide (2026)
EU AI Act Article 110 grants Union institutions, bodies, offices, and agencies a 36-month transition period from the regulation's full application date — meaning AI systems already in use within the EU Commission, Parliament, Council, and other Union bodies have until August 2, 2029 to achieve full compliance. Developer guide covering how Art.110 differs from Art.108 private-sector transitional provisions, why the EDPS rather than national competent authorities enforces compliance for Union institutions, how the AI Office oversight role under Art.91 intersects with Art.110 transition timelines, what substantial modification means in Union institution contexts, registration obligations for high-risk AI under Art.51 during the transition period, procurement implications for developers building AI systems for EU institutions, how internal governance requirements (AI strategies, inventories, impact assessments) apply during the 36-month window, the role of the Interinstitutional AI Committee, Python tooling for tracking Union institution AI compliance timelines, and a 30-item Art.110 transitional readiness checklist for developers and EU procurement teams.
2026-04-14·14 min read·sota.io team