The AI Act in 2026: questions a law firm should ask
The European timetable has changed. Firms need to identify their actual uses and the obligations relevant to them.
Use the current timetable
The European Commission states that the AI Omnibus entered into force on 27 July 2026. High-risk deadlines were moved to 2 December 2027 for Annex III use cases and 2 August 2028 for systems linked to Annex I products. The general timetable and its exceptions therefore need to be read together.
Dates alone do not establish which regime applies to a tool. Start by describing its actual use. Formatting assistance, recruitment software and a service offered to clients raise different questions.
Build an inventory people can use
Begin with tools that are actually in use, including individual subscriptions. Record the task, users, information submitted and destination of the output. A concise, current description is more useful than an elaborate spreadsheet nobody maintains.
Include a working example. “Prepare a contract summary for internal review” says more than “use AI”. That description helps the responsible lawyer examine the firm's role, the supplier's role and the relevant framework.
Ask the supplier specific questions
Ask what the product is intended to do and how its limitations are documented. Who manages model changes? How are users told about important modifications? What options exist to retrieve data and outputs after an incident?
For a developer such as Mashaah LLC, behind the AILawyer offering, this exchange is part of bringing AI into legal practice. A product's value also depends on the clarity of the answers given to the professionals using it.
Turn monitoring into useful decisions
A regulatory development may call for a contract review, a procedure change or a supplier question. It does not necessarily mean replacing every tool. Identify someone to monitor developments and explain their implications for the uses already recorded.
Training can follow the same practical approach. Work through an incorrect answer, an untraceable reference and a document containing confidential information. Staff will better remember the expected decisions when they relate to familiar tasks.
What lawyers can offer clients
This method is useful when advising a business too. Understanding actual use helps produce a supplier questionnaire, refine a clause and distinguish unknown facts from identified requirements. Monitoring AI regulation becomes a practical service grounded in the client's operations rather than a technology label.
Sources and references
General information. Application to a matter depends on its facts and the rules in force.
