The Digital Omnibus moved your AI Act deadlines. It didn’t move your obligations.

In June 2026, the EU formally adopted the Digital Omnibus on AI — the first significant amendment to the AI Act since its adoption. The headline that circulated was simple: “the EU delayed the AI Act.” Like most headlines, it is half true, and the half that is false is the dangerous part.

What actually moved

The high-risk regime — the heaviest part of the Act, covering risk management systems, data governance, technical documentation, logging, human oversight, and conformity assessment — was deferred. Standalone high-risk systems under Annex III now come into scope on 2 December 2027 rather than 2 August 2026. AI embedded in regulated products under Annex I follows on 2 August 2028.

The deferral happened for an unglamorous reason: the compliance ecosystem was not ready. Harmonised standards were running behind, notified bodies were not in place, and many Member States had not stood up their supervisory authorities. Legislators moved the date so obligations would not bite before the tools to meet them existed.

What did not move

Everything else. Prohibited AI practices have been banned since February 2025. AI literacy obligations apply to every organisation using AI. General-purpose AI rules have been in force since August 2025. And the Article 50 transparency obligations — telling people when they are interacting with AI, disclosing AI-generated content — went live on 2 August 2026, exactly as originally scheduled. They were deliberately excluded from the deferral.

How to read the extra time

The wrong lesson is that high-risk compliance can wait until 2027. Conformity work of this scale cannot be reconstructed in the final months: evidence of oversight, decisions, and controls has to be captured as it happens, not assembled retrospectively under deadline pressure. The organisations that treat the next sixteen months as a documentation window — building the inventory, assigning accountability, capturing evidence continuously — will experience December 2027 as a checkpoint. The ones that treat it as a pause will experience it as a cliff.

We maintain a full, current breakdown of every milestone on our EU AI Act Timeline page.

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