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RegulationEUJuly 27, 2026

EU Digital Omnibus on AI enters into force, deferring high-risk obligations to 2027 and 2028

In brief

The Digital Omnibus on AI entered into force on July 27, 2026. High-risk obligations for Annex III systems now apply from December 2, 2027, and for AI in Annex I regulated products from August 2, 2028. Article 50 transparency obligations still applied from August 2, 2026.

Why it matters: Many clients heard “the AI Act was delayed.” Only part of it was. Advisers need to separate the deferred high-risk regime from obligations already in force, including prohibitions, AI literacy, GPAI model rules and transparency.

The Omnibus is a deferral, not a cancellation. The substance of the high-risk regime remains; what moved is when it applies. A grace period to December 2, 2026 applies to marking AI-generated content from systems already on the market.

US firms are not automatically outside the Act: it can reach providers and deployers outside the EU where the output of an AI system is used in the EU.

Try it: our EU AI Act Risk Classifier gives a first-pass classification and the dates that apply. For the full picture, read The EU AI Act for lawyers.

General information, not legal advice. Check the primary source and any later developments before relying on this summary.

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