Shortly after the publication of the Artificial Intelligence (AI) Act, the EU Commission published the AI Pact’s draft commitments with a view of anticipating compliance with high-risk requirements for AI developers and deployers.

Publication and timeline for the AI Act

The EU AI Act was published in the Official Journal of the European Union on July 12, 2024, as “Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonized rules on artificial intelligence.”  We have presented the main provisions and purposes of the AI Act in our publication here.

The EU AI Act will enter into force across all 27 EU Member States on August 1, 2024, but has variable transition periods depending on the relevant parts of the AI Acts; starting with February 2, 2025, at which point, prohibited AI practices must be withdrawn from the market, and with the enforcement of the majority of its provisions commencing on August 2, 2026.

The call for participation on the AI Pact by the EU commission

In this context, the EU Commission issued a press release on July 22, 2024, promoting the “AI Pact”, seeking the industry’s voluntary commitment to anticipate the AI Act and to start implementing its requirements ahead of the legal deadline.  The press release can be found here.

The AI Pact was first launched in November 2023, obtaining responses from over 550 organizations of various sizes, sectors, and countries.

The AI Office has since initiated the development of the AI Pact, which is structured around two pillars:

  • Pillar I – gathering and exchanging with the AI Pact network
    Pillar I acts as a gateway to engage the AI Pact network (organizations that have expressed an interest in the Pact), encourages the exchange of best practices and provides practical information on the AI Act implementation process. This includes:
    • workshops organized by the AI Office; and
    • the creation and management of a dedicated online space for exchanging best practices.
  • Pillar II – facilitating and communicating company pledges
    Pillar II encourages AI system providers and deployers to prepare early and take action toward compliance with the requirements and obligations set out in the legislation. The commitments take the form of pledges which are ‘declarations of engagement’. These pledges contain concrete actions (planned or underway) to meet the AI Act’s distinct requirements and include a timeline for their adoption. Such declarations of engagement can also take the form of incremental objectives. This includes:
    • creating of templates and monitoring schemes;
    • organization of meetings with interested frontrunning companies; and
    • communication strategy to advertise pledges.

The EU Commission is seeking feedback from stakeholders on the draft AI Pact (the draft document can be found here) that is split into:

  • core commitments affecting all organizations that participate;
  • pledges for organizations that develop AI systems; and
  • pledges for organizations that deploy AI systems.

The commitments mostly focus on transparency obligations and requirements for AI systems that will likely be classified as ‘high-risk’ under the AI Act. By way of example, the core commitments for all organizations include:

  • adopting an AI governance strategy to foster the uptake of AI;
  • mapping of AI systems developed or used in areas that would be considered high-risk under the AI Act; and
  • promoting awareness and AI literacy of staff and other persons dealing with the deployment of AI systems on their behalf.

Tentative timeline

Organizations have until August 21, 2024 to provide comments (submissions can be made here), and a consolidated draft will be prepared before a workshop on September 4, 2024. The Commission aims to have the first signatories by October.


Disclaimer: While every effort has been made to ensure that the information contained in this article is accurate, neither its authors nor Squire Patton Boggs accepts responsibility for any errors or omissions. The content of this article is for general information only and is not intended to constitute or be relied upon as legal advice.