From the journal

EU Council and Parliament agree to simplify AI Act, extend high-risk deadlines, 7 May 2026

On 7 May 2026 the Council and Parliament reached a provisional agreement on the Commission's Digital Omnibus on AI. High-risk obligations under the AI Act will apply from 2 December 2027 for biometrics, critical infrastructure, employment, migration, and education systems, and from 2 August 2028 for AI integrated into regulated products. The grace period for synthetic-content transparency drops from six months to three.

3 min read

Co-legislators provisionally agreed on the Commission's simplification package, often called the AI omnibus. The agreement postpones, narrows, and clarifies obligations under Regulation (EU) 2024/1689. National parliamentary scrutiny and final adoption remain pending.

Application of Article 6 obligations for Annex III high-risk systems shifts to 2 December 2027. Annex I high-risk systems integrated into regulated products move to 2 August 2028. The deadline for national authorities to set up regulatory sandboxes under Article 57 shifts to 2 August 2027. Article 50 transparency rules still apply from 2 August 2026. The grace period for marking synthetic content drops from six months to three, with the new deadline on 2 December 2026. The Commission's draft Article 50 guidelines opened for consultation on 8 May 2026.

Providers of biometric identification, employment screening, education, credit-scoring, migration, and border-control AI gain time on conformity assessment, registration, and post-market monitoring. Deployers of integrated AI in machinery, toys, medical devices, and lifts gain time to align under the New Legislative Framework regime. Generative AI providers must prepare faster labelling and watermarking for content delivered to EU users. Providers facing market-entry decisions should track parliamentary plenary votes and trilogue outcomes before relying on the new dates.

The package introduces new Annex III categories, tightens definitions for general-purpose AI, and revises the prohibition list. National competent authority designations remain due 2 August 2026. The text still needs formal adoption by both institutions before entry into force. The AI Office continues to publish guidance independently.

Licentium advises providers, deployers, importers, and distributors on AI Act compliance, conformity-assessment scoping, risk classification, transparency notices, and post-market obligations, and coordinates EU counsel and notified bodies where needed. Contact us to scope a programme. Work we undertake includes AI Act gap analysis, fundamental rights impact assessments, GPAI documentation, Annex III scoping, and incident-reporting playbooks.

Source: Council of the EU, press release "Artificial intelligence: Council and Parliament agree to simplify and streamline rules", 7 May 2026, https://www.consilium.europa.eu/en/press/press-releases/2026/05/07/artificial-intelligence-council-and-parliament-agree-to-simplify-and-streamline-rules/, confirmed 15 May 2026.

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

AI Regulatory

More from the journal

See all
Illia Prokopiev

MLR Registration and the FCA Cryptoasset Gateway to 25 October 2027

This matter concerns the transition of a United Kingdom cryptoasset business from FCA registration under the Money Laundering Regulations 2017 to Part 4A permission under the Financial Services and Markets Act 2000. The question is whether MLR registration gives conversion, grandfathering, priority, or a right to continue after 25 October 2027, and what an affected firm should do before the gateway closes. This analysis assumes an existing UK-facing cryptoasset business, no relevant Part 4A permission, and an intention to continue after commencement.

Illia Prokopiev

Matched-Category Analysis of the Hong Kong Stablecoin Issuer Route and the Singapore Digital Payment Token Service Route

This matter concerns whether current licensing data supports a commercial comparison between Hong Kong’s stablecoin issuer route and Singapore’s digital payment token service route. The question is whether the proposition remains legally accurate as of 12 August 2026. “Commercially useful” is assumed to mean useful for selecting a market-entry and operating model, not proof that either regulator is more permissive.

Illia Prokopiev

ESMA's 2026 Custody Resilience CSA and the Rules That Actually Bind

ESMA’s 2026 Common Supervisory Action is a coordinated national review of digital operational resilience in crypto-asset custody. It will test whether selected crypto-asset service providers can demonstrate effective controls across six announced workstreams. The legal questions are which requirements are binding, how national competent authorities may assess control effectiveness, and what consequences may follow from a deficiency. This analysis assumes that the firm is permitted under MiCA Article 59 to provide custody and administration within Article 3(1)(17).