# AI Transitional Provisions — legal context bundle

> Curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/topics/transitional-provisions-existing-ai-systems
> Sources are cited per item. Verify against the official texts before relying on them.

The content specifically addresses AI systems already placed on the market, which raises questions about transitional arrangements, compliance deadlines, and how existing deployments are regulated differently from new systems entering the market.

## Legislation (full text of key provisions)

### AI systems already placed on the market or put into service and general-purpose AI models already placed on the marked

*Source: AI Act, aiact-art-111-en, 2024-06-12 — https://overview.legal/posts/93631*

### Recital 177 — Transitional provisions existing high-risk AI systems

*Source: AI Act, aiact-rec-177-en, 2024-06-12 — https://overview.legal/posts/94036*

In order to ensure legal certainty, ensure an appropriate adaptation period for operators and avoid disruption to the market, including by ensuring continuity of the use of AI systems, it is appropriate that this Regulation applies to the high-risk AI systems that have been placed on the market or put into service before the general date of application thereof, only if, from that date, those systems are subject to significant changes in their design or intended purpose. It is appropriate to clarify that, in this respect, the concept of significant change should be understood as equivalent in substance to the notion of substantial modification, which is used with regard only to high-risk AI systems pursuant to this Regulation. On an exceptional basis and in light of public accountability, operators of AI systems which are components of the large-scale IT systems established by the legal acts listed in an annex to this Regulation and operators of high-risk AI systems that are intended to be used by public authorities should, respectively, take the necessary steps to comply with the requirements of this Regulation by end of 2030 and by 2 August 2030.

### Recital 84 — Third parties becoming high-risk AI providers

*Source: AI Act, aiact-rec-84-en, 2024-06-12 — https://overview.legal/posts/93850*

To ensure legal certainty, it is necessary to clarify that, under certain specific conditions, any distributor, importer, deployer or other third-party should be considered to be a provider of a high-risk AI system and therefore assume all the relevant obligations. This would be the case if that party puts its name or trademark on a high-risk AI system already placed on the market or put into service, without prejudice to contractual arrangements stipulating that the obligations are allocated otherwise. This would also be the case if that party makes a substantial modification to a high-risk AI system that has already been placed on the market or has already been put into service in a way that it remains a high-risk AI system in accordance with this Regulation, or if it modifies the intended purpose of an AI system, including a general-purpose AI system, which has not been classified as high-risk and has already been placed on the market or put into service, in a way that the AI system becomes a high-risk AI system in accordance with this Regulation. Those provisions should apply without prejudice to more specific provisions established in certain Union harmonisation legislation based on the New Legislative Framework, together with which this Regulation should apply. For example, Article 16(2) of Regulation (EU) 2017/745, establishing that certain changes should not be considered to be modifications of a device that could affect its compliance with the applicable requirements, should continue to apply to high-risk AI systems that are medical devices within the meaning of that Regulation.

## Literature

### Italy’s Artificial Intelligence Act and Global AI Governance: The EU Model’s Practice and Prospects

*Source: Law and Economy, 2026-02-25 — https://overview.legal/posts/132619 — original: https://doi.org/10.63593/le.2788-7049.2026.03.004*

The Italian Artificial Intelligence Act, enacted on September 17, 2025, represents the first comprehensive national implementation of the European Union’s AI Act. This study examines the Italian legislation through the theoretical lens of multi-level governance, analyzing its dual function as both a “bridging legislation” that translates EU framework into domestic practice and a site of significant regulatory innovation. Through detailed textual analysis and case studies, particularly in healthc

### A Comparative Analysis of the EU AI Act and the Colorado AI Act: Regulatory Approaches to Artificial Intelligence Governance

*Source: International Journal of Computer Applications, 2024-09-26 — https://overview.legal/posts/132613 — original: https://doi.org/10.5120/ijca2024923954*

International Journal of Computer Applications (0975 – 8887) Volume 186 – No. 38 , September 2024 23 A Comparative Analysis of the EU AI Act and the Colorado AI Act: Regulatory Approaches to Artificial Intelligence Governance Mayur Jariwala School of Computer and Information Sciences, University of the Cumberlands, Williamsburg, KY, USA ABSTRACT This comparative study examines the EU AI Act and the Colorado AI Act, focusing on their regulatory approaches to artificial intelligence. The EU AI Act provides a comprehensive framework with a risk - based classification, emphasizing transparency, accountability, and the protection of fundamental rights across diverse sectors. It aims to set a global benchmark for AI governance, influencing international standards. The Colorado AI Act targets high - risk AI systems, prioritizing consumer protection, fairness, and the prevention of algorithmic discrimination. It mandates detailed documentation, ri sk management, and transparency measures to ensure ethical AI deployment. This analysis explores the impacts of each act on innovation, industry practices, and consumer protection, as well as their potential global influence. The findings highlig

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Generated by overview.legal · https://overview.legal/topics/transitional-provisions-existing-ai-systems · 2026-08-22