EU AI Act enforcement begins — first compliance deadlines hit European tech companies

The principle operating here, stated plainly, is: Regulatory deadlines must be enforced with absolute punctuality and without concession for the regulated party’s practical capacity, because the unflinching demonstration of legal authority is itself a necessary condition of the law’s validity. Let us ask whether this principle, universalised, produces coherence or contradiction.

Consider the world wherein every sovereign power applies this maxim. Law becomes a series of immutable temporal milestones, detached from the material conditions of those subject to it. A statute demanding the construction of a bridge in one year is enforced even if a famine strikes the engineers; a tax due on a fixed date is collected even if the payer’s harvest has failed. The very concept of law, however, presupposes that it addresses rational agents capable of conforming their will to its requirements. If the law commands what is, for a class of agents, genuinely impossible, it ceases to be a law for them and becomes a mere decree of force. Universalising this maxim thus yields a contradiction in conception: we will a system of universal legislation, yet the principle we will would strip that system of the presupposition of agency upon which legislation rests. The law, in such a world, would be a set of traps rather than rules, and a system of traps cannot be willed by a rational being seeking a lawful order. The maxim collapses under the weight of its own universal application.

Turn now to the Humanity Formula: Act so that you treat humanity, in your own person and in that of another, always as an end and never merely as a means. Who is instrumentalised here? The tech companies, and within them the engineers, managers, and workers, are reduced to mere instruments for the state’s demonstration of vigilance. Their rational project of developing safe AI - a genuine end of human welfare - is subordinated to the calendar. The state does not engage with them as co-legislators in a Kingdom of Ends, each contributing to a rational legal order; it uses them as pawns in a display of regulatory potency. The deadline becomes a whip, not a guidepost. Even if the state’s ultimate aim is the public good, the manner of enforcement - indifferent to the agent’s capacity - fails to respect that agent’s dignity as a rational being capable of setting and pursuing ends. To treat a corporation as a mere compliance unit is to treat the persons within it as mere means to the corporation’s survival, and the corporation itself as a mere means to the state’s symbolic authority.

What, then, of the Kingdom of Ends? Imagine a community of rational legislators drafting the fundamental terms of their coexistence. Would they adopt a rule that deadlines are sacrosanct regardless of feasible compliance? They would not, for they would recognise that such a rule would incentivise either reckless over-promising (to meet the letter while failing the spirit) or cynical abandonment of the project. A rational legislator, concerned with the actual realisation of the law’s telos - here, the safe development of AI - would insist on a principle that allows for graduated accountability, for verification of good-faith effort, for the adjustment of timelines in light of newly discovered technical obstacles. The community would will a law that is practicable, for an impracticable law is no law for a community of finite rational beings. The maxim under consideration would be rejected in the legislative assembly of rational wills.

The duty that emerges is not to suspend enforcement, but to enforce in a manner consonant with the respect due to rational agency. The state has a duty to provide clear, achievable benchmarks and to assess compliance with a eye to the maxim of the regulated party’s conduct. Has the company acted on a maxim of diligent, good-faith effort to meet the spirit of the regulation, even if the letter proves temporarily elusive? If so, the state’s response must be corrective and educational, not merely punitive. Punishment is justified only when the maxim of the offender is one of disregard - when the company has, from the outset, acted on the principle that the law is a mere obstacle to be circumvented. To punish a maxim of sincere striving is to treat the striving agent as a mere means to the end of deterrence, and that is impermissible.

Consequences, though not the foundation of the moral judgement, confirm the principle. A regime of rigid, context-blind deadlines will produce not compliance, but a culture of box-ticking and regulatory gaming. It will drive innovation toward deadline-meeting rather than safety-enhancing, and it will breed resentment toward the very law it seeks to uphold. Conversely, an enforcement