EU AI Act basics for law firms
What applies now, what the 2026 Digital Omnibus postponed, and when a Swiss firm may be in scope.
Informational only, not legal advice. Results reflect vendors’ public statements on the date checked and our scoring rules. Verify contracts yourself before using any tool with client data.
Who it applies to
The AI Act (Regulation (EU) 2024/1689) distinguishes mainly between providers (who develop or place AI systems on the market) and deployers (who use them professionally). A law firm using a legal AI tool is typically a deployer. The Act can also reach providers and deployers outside the EU where the output of the system is used in the EU (Art. 2(1)(c)). Whether that applies to a Swiss firm depends on the facts.
What applies already
- Prohibited practices (Art. 5) and the AI literacy duty (Art. 4) apply since 2 February 2025. As amended by the Digital Omnibus, Art. 4 requires providers and deployers to take measures to support the AI literacy of staff using AI on their behalf; no specific level is mandated. National authorities supervise it from 2 August 2026.
- The Act’s general date of application was 2 August 2026, including transparency duties under Art. 50. The Digital Omnibus on AI moved the deadline for marking AI-generated content to 2 December 2026 for systems placed on the market before 2 August 2026.
High-risk rules: postponed
Regulation (EU) 2026/1744 (Digital Omnibus on AI), in force since July 2026, sets the high-risk obligations for Annex III systems to apply from 2 December 2027 (Annex I product-embedded systems: 2 August 2028). Annex III includes AI intended to be used by or on behalf of judicial authorities to research and interpret facts and the law. Typical law-firm drafting and research tools are not listed as such, but classification depends on the intended purpose. Check each case.
Practical steps
- Keep an inventory of the AI tools your firm uses and for what.
- Document the AI-literacy measures taken for lawyers and staff.
- Ask vendors how they meet their provider obligations and transparency duties.