ComplyAir LogoComplyAir
Regulations

Understanding the dates of an EU regulation: publication, entry into force, applicability

#Eur-Lex#Applicability

When you read a European regulation, you often see several dates. And they do not mean the same thing. Understanding these nuances helps you avoid two classic mistakes:


1) Publication date (Official Journal)

This is the date on which the text is published in the Official Journal of the European Union (OJEU) (and therefore officially accessible).

A point often overlooked: the “publication date” corresponds to the moment when the Official Journal edition is actually made available to the public (in all languages) via the Publications Office.


2) Date of entry into force

This is the moment when the regulation exists legally, when it “comes into being” in law.

Very often, the wording is something like:

This Regulation shall enter into force on the twentieth day following that of its publication…

Or sometimes faster (3 days), in cases of urgency (this exists and is framed).

Important: entry into force ≠ obligations applicable immediately.
EASA summarises it well: entry into force is the date of the act’s legal existence.


3) Date of applicability

This is the date from which the regulation actually produces rights and obligations (and can therefore be applied, enforced, opposed to addressees and, where appropriate, sanctioned).

EASA puts it clearly: between entry into force and applicability, there can be a period of vacatio legis (time left for actors to adapt). That is precisely why the legislator sometimes sets two distinct dates: one for legal existence, one for applicability.


4) When applicability changes depending on the actors

This is common in aviation: for operational reasons, the text may provide different dates depending on your role/activity.

A very concrete example: Part-IS (Implementing Regulation (EU) 2023/203)

The regulation sets a general rule:

But it adds an exception for a specific actor:

👉 Takeaway: “the applicability date” is not always “one single date for everyone”.

← Back to Blog