EU AI Act after the Digital Omnibus: the new 2026 to 2028 deadlines
What the Digital Omnibus changed: high-risk duties move to December 2027 and August 2028, two new bans from December 2026, and Article 50 transparency still applies from August 2026.
What Regulation (EU) 2026/1744 is
The Digital Omnibus on AI amends the AI Act's application dates in Article 113. It was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. The dates on this page are recorded from concordant secondary reporting and the records are still pending review against the Official Journal text, so confirm each date there before you rely on it.
What already applies
The prohibited practices in Article 5 and the AI literacy duty in Article 4 have applied since 2 February 2025. General-purpose AI model duties, governance and penalties have applied since 2 August 2025; models placed on the market before that date have until 2 August 2027. General application of the Regulation began on 2 August 2026.
Article 50 transparency did not move
Chatbot disclosure, machine-readable marking of synthetic content, emotion-recognition notices and deepfake disclosure under Article 50 apply from 2 August 2026. If your product talks to people or generates content, these are live now; the Omnibus deferral is for high-risk duties only.
Two new prohibitions from 2 December 2026
The Omnibus adds two Article 5 prohibitions, on generating non-consensual intimate imagery and child sexual abuse material, applying from 2 December 2026. Add both to your prohibited-use screen.
High-risk duties: 2 December 2027 and 2 August 2028
The Chapter III obligations for stand-alone high-risk systems listed in Annex III (employment, education, credit, essential services, law enforcement, migration, justice, biometrics, critical infrastructure) now apply from 2 December 2027. For AI that is a safety component of a product covered by the Annex I product-safety laws, they apply from 2 August 2028. That covers risk management, data governance, technical documentation, logging, human oversight, accuracy and security, the quality management system, conformity assessment, registration, and the deployer duties in Article 26.
How to re-plan
Keep the Article 50 and prohibited-practice work on today's footing. Re-sequence high-risk work so documentation and testing are produced as the system is built, aiming to finish conformity assessment before December 2027. Use the extra time for the slow items: data governance evidence, the quality management system and supplier agreements under Article 25(4).
Obligations referenced in this guide
- Legal Do not deploy or provide AI for prohibited practices (EU AI Act, European Union)
- Legal Ensure AI literacy of staff operating AI systems (EU AI Act, European Union)
- Legal Establish a risk management system for high-risk AI (EU AI Act, European Union)
- Legal Complete conformity assessment, CE marking and EU database registration (EU AI Act, European Union)
- Legal Use high-risk AI as instructed, monitor it and inform affected people (EU AI Act, European Union)
- Legal Disclose AI interaction and label synthetic content (EU AI Act, European Union)
- Legal Meet general-purpose AI model provider obligations (EU AI Act, European Union)
- Legal Providers of generative AI must mark synthetic output as artificially generated in a machine-readable way (EU AI Act, European Union)
Frequently asked questions
Was the EU AI Act delayed?
Partly. Regulation (EU) 2026/1744 moved the high-risk obligations to 2 December 2027 (Annex III systems) and 2 August 2028 (AI in Annex I products). The prohibitions, AI literacy, general-purpose AI duties and Article 50 transparency were not delayed. The record is pending review against the Official Journal.
When do the EU AI Act high-risk rules apply now?
From 2 December 2027 for stand-alone high-risk systems listed in Annex III, and from 2 August 2028 for AI embedded in products covered by the Annex I product-safety laws, according to the record of Regulation (EU) 2026/1744.
Did the Article 50 transparency duties move?
No. According to the record, chatbot disclosure, synthetic-content marking and deepfake labelling under Article 50 apply from 2 August 2026.
What new prohibitions did the Omnibus add?
Two prohibitions in Article 5, on AI generation of non-consensual intimate imagery and of child sexual abuse material, applying from 2 December 2026.
Do the general-purpose AI model duties still apply?
Yes. They have applied since 2 August 2025, with models already on the market before that date given until 2 August 2027.
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.