Two developments from the past few weeks that affect Dutch professionals directly: the European AI Act entered its enforcement phase for large language models on 2 August 2026, and OpenAI has filed a confidential S-1 with the SEC as a step towards a stock market listing.
AI Act: European Commission can now impose fines
Providers of general-purpose AI (GPAI) models, such as OpenAI, Anthropic, Google and Meta, have been subject to the EU AI Act since 2 August 2025. Until this year, however, the EU AI Office had built in a transition period. That period ends on 2 August 2026.
What this means in practice:
- The European Commission may now request technical documentation, evaluate models and enforce compliance.
- For infringements, fines can reach 3% of worldwide annual turnover or a minimum of €15 million, whichever is higher.
- Models can be withdrawn from the EU market in the event of serious infringements.
In addition, there is a transparency obligation (Article 50): chatbots, voice agents and other interactive AI systems deployed in the EU must explicitly inform users at the start of an interaction that they are communicating with AI, not with a human.
For you as a user of AI tools, this has an indirect but real consequence: your model provider's compliance position becomes part of your own risk file. If you use ChatGPT, Claude or Gemini for sensitive work processes, it is wise to check whether your provider has signed the GPAI Code of Practice. Meta has not done so so far and must demonstrate compliance in other ways. You can read more about which models offer which audit guarantees on our safety page.
Point of attention: the 2026 omnibus amendment shifted the conformity assessment deadline for high-risk AI systems (e.g. HR software, credit scoring) from August 2026 to 2 December 2027. That gives more time, but it does not exempt you from the documentation obligation that already applies.
Sources: Beam.ai – GPAI enforcement August 2026 · Enterprise DNA – Fines now real · ISMS Copilot – what applies as of 2 August
OpenAI: S-1 filed, IPO in sight
On 22 May 2026, OpenAI filed a confidential S-1 with the SEC, the first step towards a stock market listing. Goldman Sachs and Morgan Stanley are advising on the process. The intended valuation lies between $852 billion and more than $1 trillion, which would make it the largest IPO ever if the upper end is reached.
Some financial figures from the prospectus:
- Monthly revenue: approximately $2 billion (annualised: $25 billion)
- Consumer subscribers: 50 million
- Business users: 9 million
- Enterprise revenue: more than 40% of total revenue
A firm listing date has not yet been set. CFO Sarah Friar said in August that the option to list in September remains open, but that OpenAI is "charting its own course" and is prepared to wait until 2027 if market conditions require it. Reuters reported at the end of June that the internal preference had shifted to 2027.
For Dutch professionals who buy ChatGPT licences, nothing changes operationally because of the IPO. What could change: a publicly listed OpenAI has shareholders who expect quarterly results, which increases pressure on pricing changes and product decisions. See also our pages on GPT models and the tools that use GPT-4o for an up-to-date overview.
Source: Calendarial – OpenAI IPO September 2026 · AIToolsRecap – S-1 filed · CNBC – CFO Friar on timing
Sources summarised: Beam.ai · Enterprise DNA · ISMS Copilot · Calendarial · AIToolsRecap