Digital Omnibus on AI enters into force: high-risk obligations postponed
2026-07-27 · Publisher : Union européenne · Domain : Artificial Intelligence
Regulation (EU) 2026/1744, the Digital Omnibus on AI, enters into force: the first amendment to the AI Act, it postpones high-risk system obligations to December 2, 2027 and August 2, 2028, without changing the general-purpose model rules.
What changes
- Annex III high-risk systems (employment, education, credit, critical infrastructure): from August 2, 2026 to December 2, 2027.
- AI embedded in regulated products (Annex I): postponed to August 2, 2028.
- Two new prohibitions, non-consensual intimate imagery and child sexual abuse material, applying from December 2, 2026.
- Article 50 transparency obligations still apply from August 2, 2026, with a limited grace period for machine-readable marking.
- The European AI Office gains investigation and penalty powers close to those of a competition authority.
On July 27, 2026, Regulation (EU) 2026/1744, known as the Digital Omnibus on AI, enters into force, three days after its publication in the Official Journal on July 24. It is the first substantive amendment to the AI Act (Regulation (EU) 2024/1689), adopted urgently a few days before the August 2, 2026 deadline for high-risk systems. ### What happened - The Commission proposed the text in November 2025 as part of its digital simplification package. Political agreement on May 7, 2026, Parliament vote on June 16, Council adoption on June 29. - The regulation also amends the EASA Regulation and the Machinery Regulation: AI embedded in machinery leaves the direct scope of the AI Act's high-risk rules. - The new dates are fixed: the Commission's original proposal, which tied them to the availability of standards, was not retained. ### New timeline | Obligation | Original date | New date | |---|---|---| | High risk, Annex III (employment, education, credit, law enforcement) | August 2, 2026 | December 2, 2027 | | High risk, Annex I (regulated products) | August 2, 2027 | August 2, 2028 | | New prohibitions (non-consensual intimate imagery, CSAM) | — | December 2, 2026 | | Article 50 transparency | August 2, 2026 | unchanged | | National regulatory sandboxes | August 2, 2026 | August 2, 2027 | ### Other changes - AI literacy (Article 4) becomes an obligation of means, not of result. - The European AI Office gains exclusive supervision of certain systems built on general-purpose models and of those integrated into very large platforms, with periodic penalties of up to 5% of average daily turnover. - Support measures extend to small mid-cap enterprises. ### Caveats The postponement is not a pause: general-purpose model rules and most transparency obligations remain in force. One law firm sums it up: "it would be a mistake for organisations to view the Omnibus as a broad pause on AI regulation." ### Key takeaways Companies gain sixteen months for Annex III high-risk systems, but the August 2026 transparency deadlines remain.
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Tags : IA, AI Act, Régulation, Europe, Omnibus numérique