EU Digital Omnibus on AI enters into force, moving the AI Act's high-risk deadlines

Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force on 27 July 2026, three days after its publication in the Official Journal on 24 July. It amends the EU AI Act to set later, fixed dates for the obligations on high-risk AI systems, adds a new prohibited practice, and simplifies several duties. The Act’s general date of application, 2 August 2026, was not changed.

What happened

The regulation, dated 8 July 2026, followed the European Parliament’s first-reading vote on 16 June and Council approval. Its main changes to the AI Act (Regulation (EU) 2024/1689) are:

• High-risk deadlines. The requirements for high-risk systems in Chapter III, Sections 1 to 3, apply from 2 December 2027 for Annex III use cases (such as employment, education and critical infrastructure) and from 2 August 2028 for AI in products covered by Annex I (such as machinery, toys and lifts).
• New prohibition. From 2 December 2026, AI systems that generate non-consensual sexually explicit and intimate content or child sexual abuse material are banned.
• Transparency. Providers of generative systems placed on the market before 2 August 2026 have until 2 December 2026 to meet the Article 50(2) machine-readable marking duty. The rest of Article 50 applied from 2 August 2026.
• AI literacy. Article 4 now requires providers and deployers to “take measures to support” AI literacy among their staff, without guaranteeing “any specific level,” and gives the Commission and Member States a duty to support them.
• Other changes. According to the Commission, some measures for SMEs extend to small mid-cap companies, an EU-level regulatory sandbox is created, registration of exempted systems is simplified, processing of special categories of personal data to detect and correct bias is permitted, and the AI Office gains oversight of certain AI systems built on general-purpose models.

Why it matters

The Commission’s November 2025 proposal would have tied the high-risk dates to the availability of standards and other support tools, with 2 December 2027 and 2 August 2028 as the latest dates; the final text fixes those dates outright, which boards and risk teams can plan against. It does not delay the prohibitions, the general-purpose AI rules or most of Article 50, which already apply. For assurance providers and AI insurance underwriters assessing EU exposure, the dates that matter for high-risk conformity work are now December 2027 and August 2028. See The Standards Landscape Explained, the timeline, and When Does AI Insurance Become Required?.

What is not yet clear

How smoothly the high-risk regime starts depends on later Commission guidance and on harmonized standards, which CEN and CENELEC were still developing when the amendment took effect. National authorities’ approach to enforcing the new prohibition from December 2026 is also not yet known.