On 2 August 2026, three strands of AI Act obligations become applicable according to our supervision monitor: the market-surveillance rules for high-risk AI under Annex III, the transparency duties under Article 50, and the database requirement under Article 71. That is eight days away.
We have been observing the official sources continuously since 12 July 2024. What our data shows at this date is three gaps. None of them is an opinion — each is a count over a named observation set, with a data state and a source. And none of them means what it appears to mean at first glance. We say that part too.
1. Not one enforcement action based on the AI Act
As of data state 23 July 2026, our AI Enforcement Monitor holds eleven officially published enforcement measures with an AI connection: five from Germany, six at EU level, across eight authorities and five jurisdictions. Six are final, three open, two under appeal. Six carry a recorded fine amount.
In none of these eleven cases is the legal basis the AI Act. Seven rest on the GDPR, one on the GDPR plus German data-protection law, two on the Digital Services Act, one on German competition law. The counted value for actions taken under the AI Act is zero.
This is expected — the penalty provisions and the supervisory structure phase in on their own schedule. It is still worth stating plainly: what is enforced against AI systems today is enforced with data-protection and platform law, not with the law named after the AI system.
2. No harmonised standard cited in the Official Journal
As of data state 21 July 2026, the AI Standardisation Monitor tracks fourteen CEN-CENELEC work items answering the European standardisation request for the AI Act, against ten derived requirements. Six are in drafting, three at enquiry, four at approval, and one is approved: EN 18286:2026.
Published: zero. Cited in the Official Journal of the EU: zero.
The second number is the one that matters. It is the reference in the Official Journal that triggers the presumption of conformity — the ability to rely on a harmonised standard to demonstrate the requirements. For none of the fourteen observed work items do we record such a reference, including the already-approved EN 18286:2026.
3. Germany's market-surveillance authority sits in an unpromulgated law
As of data state 21 July 2026, the AI Supervision Monitor records the Federal Network Agency (Bundesnetzagentur) with the status proposed. It is proposed by the German AI Market Surveillance and Innovation Promotion Bill, adopted by the Federal Cabinet on 11 February 2026 and by the Bundestag on 11 June 2026.
The procedural stage we record is adopted by parliament, not promulgated. We observe promulgation separately, because it is its own official act and does not follow from the Bundestag's approval.
At EU level, the network of national market-surveillance authorities stands at status designating in our data.
What does not follow
This boundary is not fine print. It is the condition on which the numbers above can be used at all.
- Zero measures does not mean zero proceedings. We count officially published measures in a bounded, named source set. An ongoing, unpublished proceeding is invisible in it. Absence from our observation set is not evidence of non-existence.
- No recorded reference does not mean no reference. We record the work items answering the standardisation request. If a reference appears in the Official Journal without our source showing it, it is missing here — until we observe it.
- We rate no one. These pages carry no compliance score, no readiness ranking and no effectiveness rating for any authority, federal state or provider. None of the three counts supports a statement about whether any body is meeting its obligations.
- This is not legal advice. Whether 2 August 2026 applies to you, and what follows from it, depends on your specific system and your role. That needs legal counsel, not a database.
How to check this yourself
Every figure above sits with its data state in a machine-readable dataset, and every dataset names its official source:
- Enforcement:
/data/ki-durchsetzungsmonitor/index.json - Standardisation:
/data/ki-normungsmonitor/index.json - Supervision:
/data/ki-aufsichtsmonitor/index.json
The authoritative current value is always in those files, never in this text. Citation format and terms of use: Open data.
Sources
- Bundestag: adoption of the German AI implementation bill (11 Jun 2026)
- Federal Government: cabinet decision on the implementation bill (11 Feb 2026)
- Bundesnetzagentur: market surveillance under the AI Act
- European Commission: market surveillance authorities under the AI Act
Editorially owned by Ideal Syka. Sources and method: Newsroom & method. Tips and corrections: ai@i6eal.de.
