The AI Act after the digital omnibus: what the new 2027–2028 dates change — and what still bites in 2026

On 7 May 2026 the Council and the European Parliament reached a provisional agreement on the “digital omnibus” — a simplification package that, among other things, reschedules the AI Act’s most demanding obligations. For organisations that spent the spring racing towards 2 August 2026, the practical question is not whether to relax, but what to re-sequence.

What moves

Stand-alone high-risk systems (Annex III) — employment, credit, essential services and similar use cases: obligations apply from 2 December 2027.
High-risk systems embedded in regulated products (Annex I) — from 2 August 2028.
Regulatory sandboxes — member-state establishment deadline moves to 2 August 2027.

What does not move

Prohibited practices and AI literacy — applicable since 2 February 2025. The omnibus even adds prohibitions (non-consensual intimate imagery, CSAM generation).
General-purpose AI obligations — applicable since 2 August 2025.
Transparency for AI-generated content — the omnibus sets a firm horizon of 2 December 2026, with a shortened three-month grace period.

One caveat that matters

The agreement is provisional: formal adoption by Parliament and Council is still pending. Until the amending act is published, the AI Act’s original dates remain the letter of the law. Treat the new dates as the planning baseline and the old ones as the legal fallback — and document that reasoning in your governance papers.

What we recommend doing now

Keep the AI inventory and role determination (provider vs deployer) on schedule — every later obligation depends on it.
Use the gained months for the hard parts: data governance, human-oversight design, vendor contracts.
Prepare the transparency labelling workstream for December 2026 — it is now the nearest hard date for most companies.
Update board briefings: the timeline changed, the direction did not.

Sources: Council press release, 7 May 2026 · Regulation (EU) 2024/1689 (AI Act) · EC AI Act Service Desk

This material is provided for general information and does not constitute legal, investment, tax, audit or other regulated professional advice. Its application depends on the facts, jurisdiction and current law. Verify the current status of the cited sources and obtain appropriate advice before acting.