The AI Omnibus amends Regulation (EU) 2024/1689 (the EU AI Act). It entered into force in July 2026 following political agreement on 7 May 2026. The Omnibus revises the application timetable for high-risk AI systems and adds a prohibition on AI systems designed to generate non-consensual intimate images.
The Omnibus amends Article 113 of Regulation (EU) 2024/1689 to reschedule application of Chapter III requirements governing high-risk AI systems. Under the revised schedule, systems listed in Annex III, covering biometrics, critical infrastructure, education, employment, migration, and law enforcement, must comply by 2 December 2027. Systems embedded in regulated products under EU harmonised legislation listed in Annex I must comply by 2 August 2028.
Developers and deployers of Annex III AI systems have until 2 December 2027 to complete conformity assessments, quality management systems, and post-market monitoring plans. This extends the compliance window by approximately 16 months beyond the original August 2026 deadline. Manufacturers embedding AI in Annex I regulated products, including medical devices and machinery, have until 2 August 2028.
The AI Omnibus does not defer the transparency obligations under Article 50, which apply from 2 August 2026. GPAI model obligations under Chapter V are also unaffected by the Omnibus. The Omnibus adds a prohibited practice under Article 5: AI systems designed to generate non-consensual intimate images are now banned under EU law.
Licentium advises organisations on AI Act compliance planning, including conformity assessment roadmaps for Annex III applications, GPAI model documentation, and Article 50 disclosure architecture. Contact us to discuss how the revised schedule affects your AI development or deployment programme. Work we undertake includes AI Act gap analysis, high-risk system classification, technical documentation review, notified body coordination, and post-market surveillance planning.
Source: European Commission, 'AI Omnibus enters into force,' July 2026