What changed

Regulation (EU) 2026/1744 of 8 July 2026, the Digital Omnibus on AI, entered into force on 27 July 2026. It amends the AI Act, Regulation (EU) 2024/1689, and moves the dates on which the high-risk rules begin to apply.

For stand-alone high-risk systems listed in Annex III, the date moves from 2 August 2026 to 2 December 2027. For AI built into products regulated under Annex I, it moves from 2 August 2027 to 2 August 2028.

The dates as they now stand

  1. 2 Feb 2025Prohibited practices and the AI-literacy dutyApplies
  2. 2 Aug 2025Obligations for providers of general-purpose AI modelsApplies
  3. 2 Aug 2026Transparency obligations under Article 50Applies
  4. Today · October 2026
  5. 2 Dec 2026End of the transitional period for marking AI-generated content, for systems already on the market before 2 August 2026. New prohibitions on AI that generates non-consensual intimate imagery or child sexual abuse material.Ahead
  6. 2 Dec 2027High-risk obligations for Annex III systemsAhead
  7. 2 Aug 2028High-risk obligations for AI in Annex I productsAhead

What did not move

The AI-literacy duty in Article 4 has applied since February 2025. The Omnibus rewords it: providers and deployers must take measures to support the AI literacy of their staff, and are not required to guarantee a specific level for any individual. It is a duty of effort, and it is still a duty.

The transparency obligations in Article 50 have applied since 2 August 2026. They cover, among other things, telling people when they are interacting with an AI system and marking AI-generated content. Providers whose systems were on the market before that date have until 2 December 2026 to meet the marking requirement.

The Omnibus also extends some of the relief written for small and medium-sized enterprises, such as simplified technical documentation, to small mid-cap companies.

What to do now

  1. Draw up an inventory of the AI systems in use, including those built into software you already buy.
  2. Classify each use. If one falls under Annex III, for example recruitment, worker management or creditworthiness assessment, December 2027 is your deadline and the preparation takes months.
  3. Record what you do for AI literacy: who was trained, on what, and when.
  4. Check Article 50 against any chatbot, voice agent or generated content that reaches people outside the company.

Sources

General information as at the review date. It is not legal advice on your situation.