What changed in AI governance and the AIGP exam
The latest change: EU AI Act high-risk deadlines deferred (Digital Omnibus on AI), 29 June 2026. The next date that matters is 2 December 2026: EU AI Act watermarking duty for AI-generated content applies. This page records the changes to the AIGP exam and to the laws it examines, each with its primary source, and what each one means for a candidate.
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Create a free accountWhat are the next dates that matter?
| Date | What applies |
|---|---|
| EU AI Act watermarking duty for AI-generated content applies (deferred from 2 August 2026) | |
| New EU AI Act prohibition applies: AI systems generating non-consensual sexual or intimate content, or child sexual abuse material (added by the Digital Omnibus on AI) (source) | |
| Member States must transpose the revised EU Product Liability Directive (2024/2853), which names software and AI-enabled systems as products (source) | |
| Each Member State must have at least one operational AI regulatory sandbox (deferred from 2 August 2026) | |
| EU AI Act obligations for Annex III high-risk systems apply (deferred from 2 August 2026) | |
| EU AI Act obligations for high-risk systems that are product safety components (Annex I) apply (deferred from 2 August 2027) | |
| EU AI Act obligations for AI components of large-scale EU IT systems in freedom, security and justice apply |
Dates for the EU AI Act are from Regulation (EU) 2024/1689 as amended by the Digital Omnibus on AI (see the first entry below). The full phase-in, with the fine tiers, is explained in the study guide at EU AI Act penalties and timeline.
What changed in the law?
29 June 2026: EU AI Act high-risk deadlines deferred (Digital Omnibus on AI)
The Council gave final sign-off to the Digital Omnibus on AI, agreed with Parliament and the Commission in May 2026. Obligations for high-risk systems listed in Annex III move from 2 August 2026 to 2 December 2027; obligations for high-risk systems that are safety components of products under existing EU product law (Annex I) move from 2 August 2027 to 2 August 2028; the deadline for each Member State to run at least one AI regulatory sandbox moves to 2 August 2027. Article 50 transparency duties keep their original 2 August 2026 date, except the AI-generated-content watermarking duty, which gets a four-month reprieve to 2 December 2026. The same regulation adds a new prohibited practice to the Act: AI systems generating non-consensual sexual or intimate content, or child sexual abuse material, banned from December 2026.
For the exam: The Body of Knowledge tests the timeline as facts, and the deferred dates are now the correct ones. Answer 2 December 2027 for Annex III high-risk and 2 August 2028 for product-embedded high-risk; answer 2 August 2026 for transparency duties. See EU AI Act penalties and timeline.
2 February 2026: EU AI Act: Commission implementing act on post-market monitoring due
Eighteen months after entry into force, the Act required the Commission to adopt the implementing act setting out the post-market monitoring plan template that high-risk providers will use.
For the exam: Post-market monitoring is a Domain IV topic: providers must monitor high-risk systems in use and feed what they learn back into risk management. See EU AI Act penalties and timeline.
2 August 2025: EU AI Act: general-purpose AI obligations and the penalties chapter apply
Twelve months after entry into force, obligations for providers of general-purpose AI models took effect, Member States had to have appointed their competent authorities, and the penalties chapter began to apply: up to €35 million or 7% of global annual turnover for prohibited practices, €15 million or 3% for breaches of high-risk and other operator obligations, and €7.5 million or 1% for misleading information to authorities, whichever is higher.
For the exam: The fine tiers are tested as exact figures. Know all three and the rule that the higher of the two applies. See EU AI Act penalties and timeline.
2 February 2025: EU AI Act: prohibited practices and AI literacy duties apply
Six months after entry into force, the Article 5 prohibitions on unacceptable-risk AI practices took effect, together with the Article 4 duty on providers and deployers to ensure a sufficient level of AI literacy among their staff.
For the exam: Article 4 applies to deployers of any AI system, not only high-risk ones, which is a common exam distinction. See EU AI Act risk tiers.
1 August 2024: EU AI Act enters into force
Regulation (EU) 2024/1689 was published in the Official Journal on 12 July 2024 and entered into force twenty days later. Its obligations switch on in phases from that date.
For the exam: Entry into force and application are different dates; questions turn on the difference. See EU AI Act penalties and timeline.
Has the AIGP exam itself changed?
1 June 2026: IAPP Certification Candidate Handbook v5.3.2 takes effect
The IAPP's handbook governing booking, identification, conduct, scoring and retakes moved to version 5.3.2, effective 1 June 2026. Results are reported on the 100–500 scale with 300 to pass; 85 of the 100 questions are scored and 15 are unscored pilot questions.
For the exam: The scoring and retake facts on this site were checked against this version. Re-check when the IAPP publishes the next one. See AIGP passing score.
2 February 2026: AIGP Body of Knowledge version 2.1 in force
Every AIGP exam sat from 2 February 2026 is written to Body of Knowledge version 2.1. The four-domain structure and the question ranges per domain in the exam blueprint are the current ones; material written to the earlier seven-domain outline is out of date.
For the exam: Check the version on any prep material before relying on it. The study guide, the glossary and the question bank on this site follow 2.1. See AIGP exam guide.
Frequently asked questions
Has the EU AI Act been delayed?
Partly. The Digital Omnibus on AI, given final approval by the Council on 29 June 2026, moved the obligations for Annex III high-risk systems from 2 August 2026 to 2 December 2027 and for product-embedded high-risk systems from 2 August 2027 to 2 August 2028. The prohibitions, the AI literacy duty and the general-purpose AI obligations were not delayed and already apply. Article 50 transparency duties keep their 2 August 2026 date, with only the watermarking duty reprieved to 2 December 2026.
When do the EU AI Act high-risk obligations apply?
2 December 2027 for systems listed in Annex III (biometrics, critical infrastructure, education, employment, essential services, law enforcement, migration, justice), and 2 August 2028 for high-risk systems that are safety components of products covered by existing EU product law.
Which Body of Knowledge version is the AIGP exam based on?
Version 2.1, effective 2 February 2026. It is a free download from the IAPP. Prep material written to the earlier seven-domain outline is out of date.
How often is this page updated?
When something changes: a dated legal milestone, a new Body of Knowledge or handbook version, or a regulator's decision that the exam draws on. The review date at the top is the last date every entry was checked against its source, not a routine bump.
Study the current version
The study guide, the glossary and the question bank follow Body of Knowledge 2.1 and the dates above. All 100 Domain I questions are free in the app.
AI Governance Study is an independent study aid. It does not represent a government entity: it is not affiliated with, endorsed by or authorised by any government, government agency or regulatory authority, and it does not provide government services or legal advice. Laws and frameworks are described in our own words — the official texts are listed at official sources. It is also not affiliated with, endorsed by, or sponsored by the IAPP. The AIGP name is used only to identify the exam this material helps you prepare for.