AI Act: the timeline to 2028, after the digital omnibus
The AI Act has applied in stages since February 2025. Regulation (EU) 2026/1744, known as the "digital omnibus on AI", in force since July 27, 2026, postponed the obligations for high-risk systems to December 2, 2027 (Annex III) and August 2, 2028 (Annex I). The prohibitions, AI literacy and Article 50 transparency already apply.
What already applies
| Date | What applies | Who is concerned |
|---|---|---|
| February 2, 2025 | Prohibited AI practices and AI literacy obligation (training of teams) | Providers and professional users |
| August 2, 2025 | Obligations of providers of general-purpose AI models | Model providers |
| August 2, 2026 | Article 50 transparency obligations: chatbots, generated content, deepfakes | Providers and professional users |
What the digital omnibus postponed
Published in the Official Journal on July 24, 2026 and in force since July 27, the omnibus regulation removes no category of obligation: it shifts deadlines, for lack of technical standards and national authorities ready in time.
| Obligation | Original date | New date |
|---|---|---|
| Marking of generated content, for systems placed on the market before August 2, 2026 | August 2, 2026 | December 2, 2026 |
| National regulatory sandboxes | August 2, 2026 | August 2, 2027 |
| Annex III high-risk systems: recruitment, credit assessment, life and health insurance pricing, education, biometrics | August 2, 2026 | December 2, 2027 |
| High-risk systems embedded in regulated products (Annex I) | August 2, 2027 | August 2, 2028 |
A postponement is not a pause: the requirements stay the same. Projects delivering a high-risk system in 2027 are designed now with these requirements.
What this touches in a project portfolio
The dates to put in your plans
- December 2, 2026: marking of generated content by systems already in service.
- December 2, 2027: Annex III high-risk systems, in service or placed on the market from that date.
- August 2, 2028: AI embedded in regulated products.
- For each date: which projects deliver before, which after, and which team carries the compliance work.
See what this hits in your organization
Prévoq links this kind of change to the projects, teams and contracts of your organization, with the level of evidence of each link.
Sources
- Regulation (EU) 2024/1689 on artificial intelligence · eur-lex.europa.eu · accessed October 31, 2026
- Regulation (EU) 2026/1744 (digital omnibus on AI), Official Journal of the EU · eur-lex.europa.eu · July 8, 2026
- Digital Omnibus on AI, consolidated text and recitals · artificialintelligenceact.eu · accessed October 31, 2026
- Orrick, "EU AI Act Update: Digital Omnibus Finalizes 8 Compliance Changes" · orrick.com · July 2026
This analysis presents the state of the texts and public sources at the date indicated. It does not constitute legal advice.
