EU AI Act: the new deadlines after the omnibus
AI · not reviewedWritten with AI from the sources listed, not yet editorially reviewed.
Amending Regulation (EU) 2026/1744 has been in force since 27 July 2026: high-risk obligations come later, transparency obligations do not.
The essentials in five points
- Stand-alone high-risk AI under Annex III (such as recruitment, creditworthiness, critical infrastructure) must meet its obligations only from 2 December 2027 instead of 2 August 2026.
- AI in regulated products under Annex I, Section A — such as medical devices or machinery — follows from 2 August 2028; for machinery, the requirements are to come via delegated acts under the Machinery Regulation.
- Transparency obligations under Art. 50 have applied since 2 August 2026; for generative systems already on the market before then, the grace period for machine-readable marking ends on 2 December 2026.
- New prohibitions from 2 December 2026: AI systems that generate or manipulate non-consensual intimate material or child sexual abuse material.
- The AI literacy duty (Art. 4) remains but is softened: providers and deployers must take measures rather than ensure a specific level.
What this means for businesses
The postponement buys time but is no pause: if you provide generative AI systems, machine-readable marking must be in place by 2 December 2026 at the latest, and the disclosure obligations under Art. 50 already apply. Use the time until the end of 2027 to inventory high-risk applications, appoint owners and build the documentation.
Sources · 3
- Gibson Dunn · 27 May 2026EU AI Act Omnibus Agreement — Postponed High-Risk Deadlines and Other Key Changes
- A&O Shearman · July 2026EU Digital Omnibus on AI: the wait is over but the compliance clock is running
- Haqq · 28 Jul 2026EU AI Act Amendments 2026: What Regulation (EU) 2026/1744 Changed
Links open the original source in a new tab. Figures from company statements are labelled as vendor or company figures in the text.
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