EU Adopts the Digital Omnibus on AI: High-Risk Deadlines Move to 2027 and 2028

What happened?

The EU adopted Regulation (EU) 2026/1744, known as the Digital Omnibus on AI, dated 8 July 2026 and published in the Official Journal on 24 July 2026. It amends the AI Act (Regulation (EU) 2024/1689), along with two pieces of product legislation, to simplify implementation and give more time for the high-risk regime.

What changed?

• High-risk deadlines. Obligations for high-risk systems in Annex III areas, such as employment, education, essential services and law enforcement, now apply from 2 December 2027. Obligations for AI that is a safety component of products under Annex I EU product law apply from 2 August 2028.
• Transparency. Article 50 obligations still apply from August 2026. Providers of generative AI systems placed on the market before 2 August 2026 get a short transitional period, until December 2026, for machine-readable marking of AI-generated content.
• AI literacy. The duty is reframed: providers and deployers must take measures to support AI literacy among their staff, rather than ensure a specific level.
• New prohibitions. Two practices are added to Article 5: AI systems that generate or manipulate non-consensual intimate imagery of identifiable people, and AI that generates child sexual abuse material.

Why does it matter?

The delay gives providers and deployers of high-risk AI more time for conformity work, quality management systems and technical documentation. It does not reduce the obligations themselves, and the prohibitions, GPAI model rules and most transparency duties already apply.

What should you do?

Revisit AI Act project plans against the new dates. Keep classifying systems and building the risk management and documentation machinery now. Watch for consolidated text and standards, which will determine how conformity is demonstrated. Our EU AI Act guide has the full updated timeline.