Compliance deadlines in 2027: what product teams need to design for
Gideon Awolesi ·
If you're planning your 2027 roadmap, a few dates are already set in law, and each one changes what your product's interface has to do. In 2027, the AI Act's high-risk rules reach tools used in hiring and credit scoring, and the smallest Polish businesses join KSeF. In the US, state and local governments have their first web accessibility deadline. We checked every date below against our own guides on 2 November 2026, and each section names the guide with the detail.
01The dates in 2027 and early 2028
Here are the dates in order. The two in 2028 are on the list because the usability work behind them has to start in 2027.
| Date | What applies | Who it affects |
|---|---|---|
| 1 January 2027 | The smallest Polish businesses start issuing invoices through KSeF | Invoicing and accounting software used in Poland |
| 26 April 2027 | The ADA Title II rule: WCAG 2.1 AA for state and local governments serving 50,000 people or more | Software sold to US public bodies |
| 2 December 2027 | The AI Act's high-risk requirements for systems listed in Annex III | AI used in hiring, credit scoring, or education |
| 26 April 2028 | The same Title II rule for smaller governments | Software sold to smaller US public bodies |
| 2 August 2028 | The AI Act's high-risk requirements for AI in Annex I products | AI in products like medical devices |
022 December 2027: high-risk AI in hiring, credit scoring, and education
The Digital Omnibus on AI, Regulation (EU) 2026/1744, moved the dates for high-risk systems. The systems listed in Annex III, like AI used in hiring, credit scoring, or education, now have to meet the high-risk requirements from 2 December 2027.
For the interface, the biggest change comes from Article 14, on human oversight. The people assigned to oversee the system have to be able to understand its output, override or reverse it, and stop it in a safe state. So each of those has to be a control your users can find and use. Test them with people from your user group before the date, including cases where the AI's output is incorrect, and check that they notice it and override it.
Our guide to human oversight UX for high-risk AI goes through Article 14(4) point by point.
031 January 2027: the smallest Polish businesses join KSeF
KSeF is Poland's national e-invoicing system. The largest companies have issued their invoices through it since 1 February 2026, every other VAT payer joined on 1 April 2026, and the smallest businesses join on 1 January 2027.
If your product issues or receives invoices for Polish customers, a lot of your new users in 2027 will be sole traders who haven't dealt with a KSeF rejection before. When KSeF rejects an invoice, it returns an error code and a message written for developers. On your rejection screen, explain what happened to the invoice and what the user needs to change, and put the technical details below it for their accountant.
Our guide to KSeF for international software teams covers the API, and our guide to translating technical error codes into user-facing copy covers the rejection screens.
0426 April 2027: the ADA rule for US public bodies
If you sell software to US state or local governments, the Department of Justice's 2024 rule under Title II of the ADA sets WCAG 2.1 AA as the standard. In April 2026, an interim final rule moved the compliance dates to 26 April 2027 for governments serving 50,000 people or more, and 26 April 2028 for smaller ones.
If a public body uses your product to serve the public, it needs your product to meet WCAG 2.1 AA by its date. So plan an accessibility audit and fix the gaps before then. If you also sell in the EU, the European Accessibility Act has applied since 28 June 2025, and one audit against WCAG 2.2 AA can cover both, because WCAG 2.2 builds on WCAG 2.1.
05Rules that apply before 2027 starts
Two rules already apply, so check your product against them before you plan anything new.
- Article 50 of the AI Act has applied since 2 August 2026. If your product has a chatbot or generates content, people have to be told they're interacting with an AI system. From 2 December 2026, generative systems that were already on the market also have to mark the content they produce.
- The European Accessibility Act has applied since 28 June 2025, to products and services like online shops and consumer banking apps.
06Why you need to start the 2028 work in 2027
If your AI is part of a medical device, the AI Act's high-risk requirements apply from 2 August 2028, alongside the MDR or IVDR. The usability engineering behind that takes time. You run formative tests while the design can still change, fix the use errors they find, and then run a summative evaluation on the final design.
That's several rounds of testing with real users. If you want the evidence ready for August 2028, start the formative work in 2027. Our guide to adding AI to a medical device covers how the AI Act and the MDR fit together.
07How to plan your 2027 roadmap
- Mark which of these dates apply to your product, and which flows each one affects.
- For each flow, write down what the interface has to let people do, like override an AI output or fix a rejected invoice.
- Test those flows with people from your user group, and fix the problems you find before the date.
- Keep the test records, because an auditor or a buyer may ask for them.
If your product has an AI feature, you can send us one flow and one question for our free AI audit, and within five business days you'll get a recorded walkthrough and a one-page fix list.