Intelligence Update · 12 September 2026

EU AI Act Digital Omnibus Now in Force: The Authoritative Timeline Update

Regulation (EU) 2026/1744 — the Digital Omnibus — entered into force on 27 July 2026, six days before the original Annex III deadline. It replaces any earlier compliance planning anchored to 2 August 2026 for high-risk AI. Article 50 transparency duties and AI Office enforcement powers over GPAI are live. High-risk obligations follow a new two-tier schedule. This article is the definitive AGNUS reference for the post-Omnibus timeline.

Jean-Daniel Alexis · 12 September 2026 · 12 min read · EU AI Act

The Digital Omnibus (Regulation (EU) 2026/1744) was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. It is now the authoritative amendment to the EU AI Act. Any compliance programme anchored to the original 2 August 2026 high-risk deadline must be updated. The Omnibus defers two high-risk tiers; all other obligations remain on the original schedule and are now enforced.

What changed: the Omnibus in one table

The Digital Omnibus made four substantive changes to the EU AI Act's compliance timeline:

ObligationOriginal dateNew date (Omnibus)Status
Prohibited AI practices (Article 5)
Social scoring, subliminal manipulation, real-time biometric ID in public spaces
2 February 2025 2 February 2025 (unchanged) In force — not deferred
GPAI model obligations (Articles 51–56)
Transparency, copyright policy, technical documentation for GPAI providers
2 August 2026 2 August 2026 (unchanged) In force — not deferred
Article 50 transparency duties
Disclosure when users interact with AI, deepfake labelling, chatbot disclosure
2 August 2026 2 August 2026 (unchanged) In force — not deferred
High-risk AI — Annex III stand-alone systems
Hiring, credit scoring, education, critical infrastructure, law enforcement AI
2 August 2026 2 December 2027 Deferred +16 months
High-risk AI — Annex I product-integrated systems
AI embedded in medical devices, machinery, toys, lifts
2 August 2026 2 August 2028 Deferred +24 months
Nudifier prohibition (new)
AI systems generating non-consensual intimate imagery or CSAM
Not in original text 2 December 2026 New prohibition — added by Omnibus

What is live right now (September 2026)

2 February 2025 — live

Prohibited practices (Article 5)

Social scoring, subliminal manipulation, cognitive exploitation, real-time biometric identification in public spaces. These prohibitions have been enforced since February 2025. The Omnibus did not touch them.

2 August 2026 — live

GPAI model obligations (Articles 51–56)

Providers of general-purpose AI models must maintain technical documentation, publish copyright policies, and comply with the AI Office's transparency requirements. Enforcement began 2 August 2026. Not deferred.

2 August 2026 — live

Article 50 transparency duties

All deployers of AI systems that interact with natural persons must disclose the AI nature of the interaction. Deepfakes must be labelled. Chatbot disclosure is mandatory. Enforcement is live. The Commission published its final guidance in July 2026.

What is deferred

2 December 2027

High-risk AI — Annex III stand-alone

AI systems used in employment (CV screening, interview assessment), credit scoring, education, biometric identification (non-prohibited), and critical infrastructure management. This tier covers the majority of enterprise AI deployments. Deferred 16 months from the original August 2026 deadline. The extra time is for preparation — not a licence to delay governance work.

2 August 2028

High-risk AI — Annex I product-integrated

AI embedded in regulated products: medical devices (MDR, IVDR), machinery, toys, lifts, personal protective equipment. These systems must comply with both the EU AI Act high-risk requirements and their sector-specific product regulation. The extra 24 months reflects the longer certification cycles in regulated product sectors.

2 December 2026

New: nudifier prohibition

The Omnibus added a new prohibited practice not in the original text: AI systems that generate or manipulate sexually explicit or intimate images without explicit consent, or that create CSAM. This prohibition enters force on 2 December 2026 — three months from now. Fines up to €35 million or 7% of worldwide turnover.

What the Omnibus did not change

Several elements of the AI Act compliance framework that were sometimes discussed as candidates for the Omnibus were not changed:

Action required

AGNUS Guidance

The deferral does not suspend the obligation to prepare. Organisations that were already working towards the August 2026 deadline have a 16-month extension for Annex III systems — not a reset. The compliance work already done remains valid and necessary. Organisations that had not yet begun should treat the December 2027 date as the actual deadline and begin now: risk classification, human oversight design, and technical documentation take substantially longer than the time remaining.

Three things are required immediately regardless of the deferral:

  1. Article 50 compliance is live. Review all customer-facing AI deployments — chatbots, recommendation systems, automated communications — for disclosure compliance. The Commission's July 2026 guidance sets out the implementation standard.
  2. GPAI providers must act now. If your organisation provides a general-purpose AI model — whether commercially or as part of an internal platform — GPAI obligations are in force. Technical documentation and copyright policies are not optional.
  3. December 2026 nudifier deadline. Organisations operating platforms that could host AI-generated intimate imagery must implement safeguards before 2 December 2026.

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