AI Act after the omnibus: high-risk AI obligations are postponed

Regulation (EU) 2026/1744 moved high-risk AI to 2 December 2027 (Annex III) and 2 August 2028 (Annex I).

AWhat changed

Regulation (EU) 2026/1744 (“Digital Omnibus on AI”) of 8 July 2026 amends the Artificial Intelligence Act, Regulation (EU) 2024/1689. It postpones the application of the obligations for high-risk systems, changes the AI literacy obligation, adds new prohibitions and extends relief for small and medium-sized enterprises to so-called small mid-caps as well.

BWhen

In force from 27 July 2026. High-risk systems under Annex III: 2 December 2027. Systems in regulated products (Annex I): 2 August 2028. New prohibitions: 2 December 2026.

CWho it affects

Providers and deployers of AI systems in areas such as employment, education, biometrics and access to services.
Manufacturers of products with AI components (e.g. medical devices, machinery).
Companies that use AI tools internally (AI literacy).

DWhat to do

Update your internal compliance plan: the dates for high-risk systems are now 2 December 2027 and 2 August 2028.
Do not put off obligations that already apply: prohibited practices (since 2 February 2025) and transparency under Article 50 (since 2 August 2026).
AI literacy: the law no longer requires you to “ensure a sufficient level”, but to take measures to support it — training or internal rules remain a sensible minimum.

Explanation

The obligations for high-risk AI were originally due to apply from 2 August 2026. The omnibus split them: stand-alone high-risk systems (Annex III — e.g. recruitment and assessment of employees, credit scoring, biometrics) from 2 December 2027, and AI built into regulated products (Annex I) from 2 August 2028.

Two prohibitions were added: AI systems for creating non-consensual intimate content and child sexual abuse material. They apply from 2 December 2026.

The separate “Digital Omnibus” package, which would amend the GDPR, the cookie rules and the Data Act, is still going through the legislative process — see the separate Radar item.

Sources

Last checked: 12 October 2026 · How we correct errors