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KNOWLEDGE & GUIDES

EU AI Act for Liechtenstein and the EEA: what applies when?

The EU AI Act has applied in the EU in stages since 1 Aug 2024; the AI Omnibus moves high-risk rules to 2 Dec 2027 and 2 Aug 2028. It has not yet been taken over in Liechtenstein; the government expects entry into force in the course of 2027. Timeline, risk levels, SME obligations. As of 3 Nov 2026.

Status check 3 Nov 2026 EU AI Act: in force in the EU since 1 Aug 2024 and applying in stages, high-risk rules after the AI Omnibus from 2 Dec 2027 and 2 Aug 2028, not yet taken over in Liechtenstein, entry into force expected by the government in the course of 2027

In short

  • The AI Act, the EU regulation on artificial intelligence (Regulation (EU) 2024/1689), has been in force since 1 Aug 2024 and applies in stages. Most rules have applied since 2 Aug 2026.
  • The AI Omnibus (Regulation (EU) 2026/1744, in force since 27 Jul 2026) moves the high-risk rules: Annex III from 2 Dec 2027, Annex I from 2 Aug 2028.
  • The AI Act does not yet apply in Liechtenstein. It first has to be taken into the EEA Agreement. The government expects entry into force in the course of 2027. That is a plan, not law.
  • If you offer AI systems in the EU or have AI output used there, the AI Act can already apply to you, even with a seat in Liechtenstein.

Status check 3 Nov 2026

What applies, what is coming?

Sorted briefly, with primary sources. Only what is in the Official Journal is law.

EUlaw

AI Act applies in stages

  • In force since 1 Aug 2024.
  • Prohibitions and AI literacy since 2 Feb 2025, rules for GPAI models since 2 Aug 2025.
  • Most rules since 2 Aug 2026, including transparency obligations under Art. 50 (AI Act Service Desk).

EUlaw

AI Omnibus: new deadlines

  • In force since 27 Jul 2026.
  • High-risk AI under Annex III from 2 Dec 2027, under Annex I (products) from 2 Aug 2028.
  • SME relief now also covers small mid-caps (European Commission).

LInot yet taken over

EEA takeover under way

  • According to the government the AI Act is in the EEA incorporation procedure (BuA 59/2026).
  • Under current planning, entry into force is expected in the course of 2027.
  • An implementing act is needed, a sandbox is being set up.

As of 3 Nov 2026. We update this page when things change.

Timeline: what applies when

The dates apply in the EU. For Liechtenstein they count only after the takeover into the EEA Agreement, unless a business is active directly in the EU market.

DateWhat appliesStatus
1 Aug 2024AI Act enters into forcelaw
2 Feb 2025General provisions (definitions, AI literacy) and prohibitionsapplies
2 Aug 2025Obligations for providers of GPAI models, EU-level governance, national authorities and penalty rulesapplies
2 Aug 2026Most rules, transparency obligations (Art. 50), enforcement startsapplies
2 Dec 2026New prohibitions for AI generating non-consensual sexual deepfakes or child sexual abuse material. Transition deadline under Art. 50(2) for certain systems already on the market before 2 Aug 2026law, from date
2 Aug 2027At least one AI regulatory sandbox per EU member statelaw, from date
2 Dec 2027Rules for high-risk AI under Annex III (after the AI Omnibus)law, from date
2 Aug 2028Rules for high-risk AI in products under Annex I (after the AI Omnibus)law, from date
during 2027Entry into force in Liechtenstein via the EEA Agreementgovernment plan

Sources: AI Act Service Desk, timeline, EUR-Lex 2024/1689, EUR-Lex 2026/1744, BuA 59/2026.

The four risk levels

The AI Act does not regulate "AI" as a whole, but applications by their risk (European Commission: regulatory framework for AI).

LevelExamplesWhat applies
unacceptableSocial scoring, harmful manipulation, emotion recognition at work and in schools, untargeted scraping of facial imagesProhibited (Art. 5), since 2 Feb 2025
highAI in recruitment, education, credit scoring, critical infrastructure (Annex III) or in regulated products (Annex I)Risk management, data quality, documentation, human oversight; from 2 Dec 2027 and 2 Aug 2028
transparencyChatbots, AI-generated content, deepfakesDisclose that people are talking to AI; label content (Art. 50), since 2 Aug 2026
minimalFor example spam filters or AI in video gamesNo additional obligations under the AI Act

What does this mean for SMEs?

  • AI literacy: Since 2 Feb 2025, providers and deployers of AI systems in the EU should ensure sufficient AI literacy of their staff (Art. 4). The AI Omnibus simplified this obligation; the Commission and member states take a stronger role.
  • Transparency: If you use a chatbot or publish AI content, you must disclose or label it in the EU since 2 Aug 2026 (Art. 50).
  • Check for high risk: Using AI to screen job applications, for example, falls under employment, i.e. Annex III. These obligations apply in the EU from 2 Dec 2027.
  • Relief: For fines, SMEs get the lower of the two amounts (Art. 99). The AI Omnibus extends SME relief to small mid-caps and widens access to sandboxes.
  • Fines: up to €35m or 7% of worldwide annual turnover for prohibited practices, up to €15m or 3% for other obligations, up to €7.5m or 1% for incorrect information (Art. 99).

Practical tip (not a legal obligation, but how we work): list which AI tools you use for what, who operates them and where results reach clients or applicants. That's the basis for any further check.

Status in Liechtenstein

  • EEA takeover: The EFTA EEA-Lex register lists the AI Act as "under scrutiny". There is no EEA Joint Committee decision yet (EFTA EEA-Lex, as of 3 Nov 2026).
  • Government: "Under current planning, entry into force is expected in the course of 2027" (our translation). The exact date depends on the EEA takeover (BuA 59/2026, 12 May 2026, German).
  • Implementation: According to an interview on digital-liechtenstein.li an implementing act is needed and a sandbox is being set up. Judith Sild: "We hope the takeover process can be completed in the course of next year" (our translation; digital-liechtenstein.li, 27 Jul 2026, German).
  • Relevant today: According to the same interview, the market location principle applies. If you are active with AI in the EU market, you already have to follow the EU rules there.
  • Other frameworks: The national administration has its own AI strategy (AI strategy of the national administration, version 1.0, German). Liechtenstein has signed the Council of Europe Framework Convention on AI (Council of Europe).

From practice: go-lives and cases

What we build ourselves with AI. Client names only where the client published them; cases stay anonymised.

digihub · In der Specki 3, Schaan

AI in your own business: where do we start?

We don't start with a tool, we start with a bottleneck: which workflow eats noticeable time today? Then we build a pilot with real examples from your daily work and bring it into operation (The Automation Layer). The first conversation takes 30 minutes and is non-binding.

Prefer to work on site? At digihub in Schaan there's coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community.

Not legal advice. Whether and how a rule applies to your business is a question for a qualified adviser. As of 3 Nov 2026.

Content from digihub.li · reviewed 3 November 2026.

FREQUENTLY ASKED QUESTIONS

Questions and answers.

Since when does the EU AI Act apply?

The AI Act has been in force since 1 Aug 2024 and applies in stages: prohibitions and AI literacy since 2 Feb 2025, rules for GPAI models since 2 Aug 2025, most rules since 2 Aug 2026. After the AI Omnibus, high-risk rules apply from 2 Dec 2027 (Annex III) and 2 Aug 2028 (Annex I).

When will the AI Act apply in Liechtenstein?

Only after it is taken into the EEA Agreement. According to the government (BuA 59/2026), under current planning entry into force is expected in the course of 2027. That is a plan, not law.

What did the AI Omnibus change?

Regulation (EU) 2026/1744 has been in force since 27 Jul 2026. It moves the high-risk rules to 2 Dec 2027 and 2 Aug 2028, simplifies the AI literacy obligation and extends SME relief to small mid-caps.

What fines does the AI Act provide for?

Up to €35m or 7% of worldwide annual turnover for prohibited practices, up to €15m or 3% for other obligations, up to €7.5m or 1% for incorrect information. For SMEs the lower amount applies (Art. 99).

How can I get to know digihub in Schaan?

Come by for a coffee at In der Specki 3 in Schaan, or try the hub with a Day Pass. Write to us via the contact form and we'll set a time.

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