Guides · Updated 2026-10-22
The Digital Omnibus delayed the AI Act. Here's what still applied on 2 August 2026.
A lot of businesses read “AI Act delayed” in the summer of 2026 and stopped preparing. The delay is real but narrow. This is the timeline as it stands after the Digital Omnibus on AI entered into force on 27 July 2026.
What moved
| Obligation | Original date | New date |
|---|---|---|
| High-risk AI systems listed in Annex III (hiring, credit scoring, education, biometrics…) | 2 August 2026 | 2 December 2027 |
| High-risk AI embedded in regulated products, Annex I | 2 August 2027 | 2 August 2028 |
| Machine-readable marking (50(2)) for generative systems already on the market before 2 August 2026 | 2 August 2026 | 2 December 2026 |
| National regulatory sandboxes | 2 August 2026 | 2 August 2027 |
The Omnibus also widened SME simplifications to a new “small mid-cap” tier and softened the AI literacy duty into a support-oriented one.
What did not move
- Article 50(1), chatbot disclosure. Applied on 2 August 2026 for everyone, including systems that were already live.
- Article 50(3) and 50(4): emotion recognition notices, deepfake labels, public-interest text labels. Applied on 2 August 2026.
- Marking of synthetic content for new generative systems placed on the market from 2 August 2026.
- The GPAI model obligations in force since 2 August 2025.
- The GDPR, which never stopped applying to the conversation data your chatbot collects.
What this means for a small site
If you run an AI chatbot, the notice should already be in place. If you publish AI images or text, check whether any of it falls under the deepfake or public-interest rules. The high-risk delays are irrelevant to most shops, clinics and SaaS companies, because their systems were never high-risk to begin with.
Sources: Regulation (EU) 2024/1689 (AI Act); Regulation (EU) 2026/1744 (Digital Omnibus on AI); Commission guidelines on Article 50 of 20 July 2026.
General information, not legal advice. Check the Regulation text and the Commission's guidelines, or ask a lawyer, for your case.