AI Act after the Digital Omnibus: the new dates

Published 19 October 2026 · By Dazr

Regulation (EU) 2026/1744 moved the AI Act's high-risk rules to December 2027 and August 2028. Transparency duties have applied since 2 August 2026.

The Digital Omnibus on AI, Regulation (EU) 2026/1744, was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. It amends the AI Act (Regulation (EU) 2024/1689) and changes when several of its obligations apply.

Already applying

2 February 2025: the prohibited practices (Article 5) and AI literacy (Article 4).
2 August 2025: the rules for general-purpose AI models, the governance bodies and the penalty regime.
2 August 2026: the transparency duties of Article 50, for example telling people they are talking to a chatbot and marking AI-generated content. The Omnibus did not move this date.

Moved by the Omnibus

High-risk AI systems in Annex III (for example in recruitment and HR, education, credit scoring and access to essential services): from 2 December 2027 instead of 2 August 2026.
High-risk AI in products under Annex I (such as machinery, toys and medical devices): from 2 August 2028 instead of 2 August 2027.

New

2 December 2026: two new prohibitions, on AI systems that generate non-consensual intimate or sexual images of identifiable people and on systems that generate child sexual abuse material.
Until 2 December 2026, generative systems placed on the market before 2 August 2026 have extra time for the marking duty of Article 50(2).
AI literacy remains a duty, in a softer form: providers and deployers must take measures to support the AI literacy of their staff, without having to guarantee a specific level.

What this means for most organisations

Most companies use AI tools rather than build them. For them, the priorities this year are an inventory of AI tools in use, a check against the prohibitions, a recorded AI literacy briefing and the Article 50 transparency checks. Annex III use cases, such as CV screening, can be planned for the deployer duties that apply from 2 December 2027.

The full timeline, with what changed and what did not: AI Act timeline after the Digital Omnibus.

Sources

For information only, not legal advice. Last updated 19 October 2026.

Topics: AI Act, Digital Omnibus, EU

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