The high-risk deferral to 2 December 2027 reads like breathing room. Worked backwards, it is less generous. A full conformity programme — gap assessment, quality management, technical documentation, testing and, where needed, third-party assessment — commonly takes twelve to eighteen months.
The standards that make that work efficient are targeted for Q4 2026, and their Official Journal citation comes later still. A team waiting for cited standards before starting could find the runway consumed before it begins.
The conditional early-application mechanism sharpens the point. If the Commission confirms readiness, high-risk rules can apply before the backstop. The prudent reading treats December 2027 as the latest plausible date, not the planning date.
Analysis is original writing by the euaicompliant desk. Not legal advice — the binding text is on EUR-Lex.