The AI Act timeline after the Digital Omnibus

The ”Digital Omnibus” simplification package postponed several AI Act deadlines. Here are the markers — to be confirmed, as the timeline remains in flux.

The key deadlines

• Transparency obligations (limited risk): apply earlier, around August 2026.
• High-risk “Annex III” (standalone systems, for example credit): pushed to 2 December 2027.
• High-risk “product” (Annex I): around August 2028.

(Dates from the Digital Omnibus adopted mid-2026 — check the version in force.)

What the deferral does not change

Your system’s classification does not move: if a model is high-risk, it stays high-risk. The deferral buys time to document, not an exemption.

What to do now

1. Inventory your AI systems (many organisations lack this list).
2. Classify each one (high risk? limited? minimal?).
3. For high-risk systems, fill the data dossier before the deadline, not at it.

Indicative guidance, not legal advice. Timeline subject to change.