The AI Act omnibus is adopted: the new dates are law

On 8 July 2026 the EU adopted Regulation (EU) 2026/1744, the Digital Omnibus on AI, which amends the AI Act, Regulation (EU) 2024/1689. It enters into force on 27 July 2026. This piece updates our May analysis, written after the political agreement of 7 May 2026: the dates agreed then are now binding law, and you can put them in front of the board without a caveat.

What moves

Three deadlines shift. High-risk systems under Annex III, the stand-alone list covering areas such as employment, credit and education, were due on 2 August 2026 and will now apply from 2 December 2027. High-risk systems embedded in products covered by EU product legislation (Annex I) move to 2 August 2028. Member states get until 2 August 2027 to set up regulatory sandboxes.

Article 50, the transparency rules for chatbots, synthetic content and deepfakes, gets a split calendar instead of a shift. Systems placed on the market before 2 August 2026 have until 2 December 2026 to comply. Systems placed on the market from 2 August 2026 must comply from day one. If you launch in September, there is no grace period for you.

What does not move

The prohibitions on certain AI practices have applied since 2 February 2025. Obligations for general-purpose AI (GPAI) models have applied since 2 August 2025. Everything the omnibus does not name keeps the original schedule from 2 August 2026. Read that list twice: the amendment is narrower than the May headlines suggested.

The trap in “we have more time”

Here is the scene we expect in many companies this month. The AI project steering group meets, someone opens the plan, crosses out 2 August 2026 and writes 2 December 2027 across the whole page. That is the mistake. The postponement works per system, and only after that system has been classified.

Which deadline is yours depends on where each use case sits: Annex III high-risk, product-embedded high-risk, transparency-only under Article 50, GPAI, or out of scope. Without an inventory and a documented classification you cannot know. A customer chatbot shipping in October falls under Article 50 immediately. A recruitment scoring tool got sixteen months more. Your GPAI-based obligations changed not at all. Three different answers inside one company, and the calendar only sorts itself once the classification is done.

What we recommend now

Four actions for the next two weeks.

Rewrite the compliance calendar directly from the regulation and retire every date that came from the May coverage. One page, ready for the board.
Finish or refresh the AI inventory: every system, model and use case, with a named owner. Tools bought since spring belong on it too.
Classify each entry: Annex III, Annex I product, Article 50, GPAI, out of scope. Write the applicable date next to each line.
Flag anything launching after 2 August 2026 with user-facing AI or generated content, and route it through a transparency check before release.

The extra months help with remediation. Classification comes first, because without it you cannot even read the calendar.

Sources: Regulation (EU) 2026/1744 (Digital Omnibus on AI) · Regulation (EU) 2024/1689 (AI Act)

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.