The Digital Omnibus pushes AI Act high-risk obligations back to 2027 and 2028. Prohibitions, transparency and AI literacy remain: here is what to do now.
The Digital Omnibus on AI, proposed by the European Commission on 19 November 2025 and adopted by the Council in June 2026, has postponed the AI Act obligations for high-risk artificial intelligence systems. It is good news for anyone using AI for recruitment, credit or education, but it is not a general suspension: prohibitions, transparency and the rules on general-purpose models keep their original deadlines.
| Obligation | Before | After the Digital Omnibus |
|---|---|---|
| Annex III high-risk systems (employment, credit, education, essential services) | 2 August 2026 | 2 December 2027 |
| High-risk systems embedded in regulated products (Annex I) | 2 August 2027 | 2 August 2028 |
| Marking of generated content, for systems already on the market before 2 August 2026 | 2 August 2026 | 2 December 2026 |
The extra time is best spent preparing, not putting things off: take inventory of the AI systems in use, classify them by risk, bring the systems that talk to customers into line with the transparency rules straight away, and train your people. You will find all the steps in our complete guide to the EU AI Act for businesses.
It simplifies and postpones some parts, especially those on high-risk systems, and rewords the AI literacy obligation in a more flexible way. It does not remove the prohibitions, the transparency obligations or the rules on general-purpose models.
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