Quick answerNov 13, 20264 min read

Which AI and quantum deadlines affect our vendors?

CR

CyberRank Research

Two sets of dates now shape vendor risk. Under the EU AI Act, transparency duties apply from 2 August 2026 and Annex III high-risk duties from 2 December 2027. For quantum, the EU asks for planning by the end of 2026, and NIST deprecates quantum-vulnerable algorithms after 2030 and disallows them after 2035. CyberRank shows where each vendor stands against both today.

TL;DR

  • AI Act: 2 August 2026 transparency, 2 December 2027 Annex III high-risk, 2 August 2028 AI in Annex I products.
  • Quantum: EU planning by the end of 2026; NIST deprecation after 2030 and disallowance after 2035.
  • Each date only helps once it reaches your vendor tiers, questionnaires, contracts and monitoring.
  • CyberRank tracks vendors' AI use and quantum-crypto posture (Beta) so you can measure them against the dates.

The answer, piece by piece

Where each set of dates is covered
AI Act datesShort answer2 Aug 2026 transparency; 2 Dec 2027 Annex III high-risk; 2 Aug 2028 Annex IRead moreAI Act dates after the 2026 OmnibusHow CyberRank helpsCandidate AI Act level per vendor (Beta)
Post-quantum datesShort answerEU planning by end of 2026; NIST deprecates after 2030, disallows after 2035Read morepost-quantum deadlinesHow CyberRank helpsQuantum-crypto posture per vendor (Beta)
Turning dates into vendor workShort answerPut the dates into tiers, questionnaires, contracts and monitoringRead morethe TPRM lifecycleHow CyberRank helpsNightly reassessment and change events

The deadlines in one table

AI Act and post-quantum dates, 2026 to 2035
2 Aug 2026SourceEU AI ActWhat appliesArticle 50 transparency duties; Commission enforcement for GPAIWhat to ask vendorsWhich features generate content, and how is it marked?
2 Dec 2026SourceEU AI ActWhat appliesContent marking for generative systems already on the marketWhat to ask vendorsThe same, for products you already use
End of 2026SourceEU PQC roadmapWhat appliesTransition planning and cryptographic inventories beginWhat to ask vendorsDo you have a cryptographic inventory?
2 Dec 2027SourceEU AI ActWhat appliesHigh-risk duties for Annex III areasWhat to ask vendorsEvidence for uses that are high-risk candidates
2 Aug 2028SourceEU AI ActWhat appliesHigh-risk duties for AI in Annex I productsWhat to ask vendorsThe same, for AI built into products
2030SourceNIST, EU roadmapWhat appliesQuantum-vulnerable algorithms deprecated; EU high-risk use cases protectedWhat to ask vendorsWhen will key exchange be post-quantum?
2035SourceNISTWhat appliesQuantum-vulnerable algorithms disallowedWhat to ask vendorsWhen will certificates and signatures follow?

AI Act dates

The Digital Omnibus on AI, in force since 27 July 2026, moved the high-risk dates back; prohibited practices and GPAI duties already apply. For vendor risk, 2 December 2027 is the main line: by then you should know which vendors' AI falls in an Annex III area and what evidence their providers hold. Each date is explained in detail in our article about the EU AI Act and your vendors.

Post-quantum dates

NIST's transition document became final on 27 October 2026. Because recorded traffic can be decrypted later, key exchange comes first and certificate signatures follow. The dates and the order of work are explained in detail in our guide to quantum security and post-quantum cryptography.

Turning dates into vendor work

A date only helps if it reaches the vendor lifecycle: tier vendors so you know who to ask first, add the questions at assessment, write dates and notice of changes into contracts, and monitor between reviews. The six lifecycle stages are explained in detail in our guide to third-party risk management.

Where CyberRank does not help

CyberRank does not tell you which legal dates apply to a specific system; your legal team should confirm AI Act dates against the consolidated text. It cannot confirm a vendor's migration plan or its AI Act compliance. It shows where each vendor stands today, from public evidence.

References

  1. Digital Omnibus on AI, Regulation (EU) 2026/1744
  2. NIST IR 8547: Transition to Post-Quantum Cryptography Standards
  3. Coordinated Implementation Roadmap for the Transition to Post-Quantum Cryptography (EU)

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