Yes, but only the high-risk obligations. The Digital Omnibus on AI, Regulation (EU) 2026/1744, in force since 27 July 2026, moved stand-alone (Annex III) high-risk obligations to 2 December 2027 and product-embedded (Annex I) ones to 2 August 2028. Prohibitions, AI literacy, general-purpose AI rules and Article 50 transparency duties are already in force.
The Omnibus was agreed in trilogue in May 2026, adopted on 8 July and published in the Official Journal on 24 July 2026. It moves the dates; it does not remove the high-risk obligations or reduce what they will require. Risk management, data governance, technical documentation, human oversight and conformity assessment all still arrive, just later.
The practical risk is reading "delayed" as "later problem". High-risk compliance means evidence produced over time, such as logs, test results and oversight records, which cannot be created the month before the deadline.
| Date | What applies |
|---|---|
| 2 Feb 2025 | Prohibited practices (Art. 5); AI literacy (Art. 4) |
| 2 Aug 2025 | General-purpose AI model obligations |
| 2 Aug 2026 | Transparency obligations (Art. 50) |
| 2 Dec 2026 | End of Art. 50(2) marking grace period for systems already on the market |
| 2 Dec 2027 | High-risk: stand-alone systems (Annex III) |
| 2 Aug 2028 | High-risk: AI in regulated products (Annex I) |
Since 2 February 2025: the Article 5 prohibitions, and the Article 4 AI literacy duty. The Omnibus kept AI literacy as an obligation on providers and deployers but softened it to taking measures to support their staff's literacy.
Since 2 August 2025: obligations on providers of general-purpose AI models.
Since 2 August 2026: Article 50 transparency. People must be told when they are interacting with an AI system; deepfakes and certain AI-generated text must be disclosed. Generative systems already on the market before 2 August 2026 have until 2 December 2026 for the machine-readable marking requirement in Article 50(2).
Under Article 99: up to €35m or 7% of worldwide turnover for prohibited practices; up to €15m or 3% for most other breaches, including transparency; up to €7.5m or 1% for supplying incorrect information to authorities. For SMEs, the lower of the two amounts applies.
Board reporting, AI governance, DPDP readiness or CMMC. Tell me which and what the constraint is.
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