107 days to the first EU AI Act deadline: what a Swiss SME has to do

The EU AI Act entered into force on 1 August 2024. Its first binding obligations apply from 2 February 2025 — 107 days from today. For most Swiss SMEs the honest answer is that very little applies, and the small part that does applies to everyone.

What actually starts on 2 February 2025

Two things, not the whole Act.

Prohibited practices. A short list of uses banned outright: social scoring, untargeted scraping of facial images to build recognition databases, emotion inference in the workplace and in education, and certain manipulative or exploitative systems. Most SMEs are not doing any of this. Read the list once anyway, because the workplace emotion-inference ban catches some HR and call-centre analytics products that are sold as ordinary tooling.

AI literacy. Providers and deployers must ensure staff dealing with AI systems have a sufficient level of understanding. This one does apply broadly, and it is the obligation companies are most likely to overlook.

The heavier machinery arrives later: general-purpose AI obligations from 2 August 2025, high-risk system requirements from 2 August 2026.

Does it reach Switzerland at all?

Switzerland is not in the EU, so the Act does not apply through Swiss law. It reaches Swiss companies through its extraterritorial scope: if you place an AI system on the EU market, or if the output of your system is used in the EU, you are in scope regardless of where you sit.

A Zurich engineering firm running an AI tool purely internally is generally outside. The same firm selling a product with an AI feature to German customers is generally inside.

Separately, the revised Swiss Data Protection Act has applied since 1 September 2023, and it governs the personal data in your prompts today, with no countdown required.

A proportionate response before February

• Write down which AI tools are actually in use. Include the ones nobody approved.
• Check them against the prohibited-practices list. Fifteen minutes.
• Decide whether any of them touch the EU market. If none do, note that conclusion and the date.
• Give the people who use these tools a short, written briefing. That is your AI literacy evidence, and it is cheap now and awkward to reconstruct later.

That is a morning’s work, not a compliance programme. The companies that will struggle in 2026 are the ones that still cannot list their AI tools in 2025.