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Digital Omnibus on AI Delays High-Risk Rules To December 2027

Brussels: The Digital Omnibus on AI will push the AI Act’s high-risk obligations for standalone systems from 2 August 2026 to 2 December 2027, under a deal that Parliament and Council negotiators reached on 7 May 2026. Parliament voted to adopt the text on 16 June, according to law firm Sidley, and formal Council approval was expected in the following weeks.

The Digital Omnibus on AI sets two new dates. Annex III systems, such as those used in recruitment and employment decisions, move to 2 December 2027. High-risk AI embedded in regulated products, including medical devices, moves from 2 August 2027 to 2 August 2028. The CMS analysis of the provisional agreement lists both dates.

Transparency duties change more narrowly. Providers of generative AI systems that reached the market before 2 August 2026 get until 2 December 2026 to meet the watermarking requirement in Article 50(2). Other transparency obligations, including those for deployers, still apply from 2 August 2026, as Hogan Lovells points out.

The deal adds a new ban. AI systems that generate non-consensual intimate imagery or child sexual abuse material, including so-called nudifier apps, face a prohibition that applies from 2 December 2026. Sidley and CMS both report that date, and Hogan Lovells says Parliament and Council had each proposed the ban in March 2026.

Smaller companies gain relief. The agreement extends certain SME flexibilities to small mid-cap companies, reduces administrative burdens and improves access to regulatory sandboxes, with the sandbox deadline moving to 2 August 2027. The Commission must also publish guidelines on overlaps with sectoral legislation by 1 August 2027, according to CMS, which matters for makers of machinery and medical products.

Not every detail is settled in public sources. The law firm notes written in May and June describe an agreement, not a published act, and they use “would” for the 2027 and 2028 dates. Companies should therefore confirm in the Official Journal that the Digital Omnibus on AI has entered into force, which happens three days after publication, according to Sidley.

For employers and software vendors, the Digital Omnibus on AI changes planning more than it changes duties. Firms that screen job applicants, score credit or manage workers with AI now have roughly sixteen extra months before the high-risk rules apply, although the obligations themselves remain in the law.

The delay buys time but removes no obligations. Compliance teams should keep building risk-management files, data-governance records and human-oversight procedures, because the December 2027 date will arrive quickly. The Digital Omnibus on AI changes the calendar, not the direction of the AI Act.