Machinery AI timeline: 2027 vs. 2028

The two dates

Date	What applies	What it does not mean
January 20, 2027	The Machinery Regulation applies. AI-related functions that affect safety, control or conformity are examined against its essential requirements in Annex III.	It does not apply the full AI Act high-risk framework to machinery.
August 2, 2028	The delegated acts under Article 8 are to apply, adding AI-specific requirements drawn from the AI Act to Annex III. The same date is the AI Act high-risk date for products in Annex I Section A.	It is not the start of AI assessment for machinery; it adds requirements to an assessment that began in 2027.

How it applies

• Structural shift: The Digital Omnibus on AI moved the Machinery Regulation from Section A to Section B of Annex I to the AI Act (Recital 42 of Regulation (EU) 2026/1744). AI requirements for machinery now reach manufacturers through machinery law, not through the AI Act's product regime directly.
• From 2027: Annex III of the Machinery Regulation already covers control systems, protection against corruption, integrity of safety logic, reliability of protective measures, ergonomics and cybersecurity aspects of control behavior. An AI-enabled machine function that affects safety or control is assessed against these.
• Until machinery standards exist: The transitional presumption of conformity lets manufacturers draw on AI Act harmonized standards or common specifications.
• Date correction: The first Official Journal version of the Machinery Regulation said January 14, 2027 in three places; the corrigendum of July 4, 2023 set the correct date, January 20, 2027.
• Technical documentation: Plan the technical file for AI functions now — risk assessment, safety argument and evidence for learning or adaptive behavior. Treating AI functions as open items until 2028 risks late redesigns, assessment delays and gaps in the file.

Compared with the USA, Canada and China

None of the other three has a machinery-specific AI rule with fixed dates. In the USA, AI in machinery falls under OSHA duties and voluntary consensus standards, with the NIST AI RMF as voluntary guidance. Canada relies on provincial occupational health and safety law and CSA standards. China regulates machinery through GB standards and CCC certification, while its AI rules target online services. The EU is the only jurisdiction where AI requirements are built into machinery conformity assessment.