Lead Analysis
Regulation6 min

On August 2, the EU starts fining AI companies up to 3% of global revenue; California joins on the same date

Advogada de compliance trabalhando tarde em departamento jurídico de banco em Frankfurt, cercada de documentação regulatória de IA em monitores e caderno com anotações manuscritas

The 12-month adaptation period for general-purpose AI providers ends on August 2, 2026. Starting this date, the EU AI Office can impose fines of up to 3% of global revenue on models such as those from OpenAI, Meta, and Google DeepMind.

The obligations of the European Union's Artificial Intelligence Regulation for general-purpose models have been in effect since August 2, 2025. What changes this Saturday is the end of the 12-month adaptation period. From August 2, 2026, the EU AI Office can formally exercise its powers of oversight and enforcement: request technical documentation, conduct model assessments, enforce compliance measures, and impose fines of up to 15 million euros or 3% of global annual revenue, whichever is greater.


OpenAI, Anthropic, Google DeepMind, Microsoft, IBM, and Mistral AI are among the 26 organizations that have signed the GPAI Code of Conduct, ensuring them a streamlined compliance pathway. Meta, the only major Western AI company that refused to sign the code in July 2025, arguing that it introduces legal uncertainties and exceeds the limits set by the AI Regulation itself, remains under the standard enforcement regime, without the benefits provided to signatories by the code.


In addition to the GPAI obligations, Article 50 of the regulation comes into effect on the same date. New AI systems that directly interact with users must disclose this in accessible language. Synthetic content and deepfakes must be labeled as such. Emotion recognition systems and biometric categorization have specific disclosure obligations. Systems already on the market before August 2 have until December 2, 2026, to adapt.


What the Digital Omnibus Changed in July


On July 8, 2026, the European Commission signed the Digital Omnibus, a regulatory package that postponed deadlines for high-risk AI systems. Autonomous systems listed in Annex III of the regulation now have until December 2, 2027, to comply; AI systems embedded in products regulated by Annex I have until August 2, 2028. The delay was a direct response to industry pressure regarding the impracticality of the original deadlines for systems in health, transportation, and critical infrastructure.


What the Omnibus did not touch: enforcement for general-purpose models and the set of transparency obligations in Article 50. For these two blocks, the deadline is upon us tomorrow without extension.


California joins on the same date, and this is not a coincidence


California's AI Transparency Act, AB 853, also becomes operational on August 2, 2026. The original deadline for AB 853 was January 1, 2026; the extension was explicitly justified to align California's law with the European date. The law requires AI platforms with over 1 million monthly users to provide a free tool for detecting AI-generated content and to incorporate identification metadata in synthetic images, videos, and audio, with transparency obligations also extended to licensed third parties.


The combined effect of August 2 is the creation of a global de facto transparency standard. Any AI provider with an audience in both the European Union and California, a category that encompasses practically every relevant language model in today’s market, must comply with materially equivalent obligations on the same day, in both jurisdictions.


Two regimes, concentrated pressure on Meta


In Europe, the first practical test for the AI Office will be setting priorities. Without a formal complaint or documented incident, it is unlikely that the Office will initiate ex officio proceedings in its first week of effective enforcement: what is expected are requests for technical documentation from model providers, not immediate fines.


In the United States, the California pathway is different. AB 853 did not create a specialized body: enforcement depends on the state Attorney General, which tends to generate more reactive actions focused on publicly reported incidents rather than routine technical oversight.


Meta faces both issues simultaneously. By refusing the European GPAI Code, it forwent the simplified compliance pathway just as enforcement begins. Its image generation products and the Llama models, which have global distribution and tens of millions of monthly users, fall under the transparency obligations of both jurisdictions. The combination of European enforcement without the benefit of the voluntary code and the California law coming into force simultaneously does not affect any other major Western AI provider to the same extent.

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