The Digital Omnibus on AI, published in the Official Journal of the EU as OJ L 2026/1744, entered into force on 27 July 2026. It amends the AI Act (Regulation (EU) 2024/1689) and is binding across all EU member states from that date. The Commission proposed the AI Omnibus on 19 November 2025 as part of its digital simplification package. The AI Act prohibition rules, which apply from 2 February 2025, are unaffected.
High-risk AI rules now apply from 2 December 2027 for systems in the sectors listed in Annex III of the AI Act. Those sectors include biometric identification, critical infrastructure, education, employment, access to essential services, law enforcement, migration, border control, and justice administration. The original deadline was 2 August 2026. AI embedded in regulated products (machinery, medical devices, toys, lifts) faces a further extension to 2 August 2028. Generative AI systems placed on the EU market before 2 August 2026 have a marking-obligation grace period until December 2026.
Providers and deployers of high-risk AI systems in the EU now have additional time to complete conformity assessments, prepare technical documentation, register systems in the EU AI database, and put post-market monitoring in place. Affected parties include HR technology vendors, automated credit-scoring and loan underwriting platforms, biometric identity verification services, AI-assisted recruitment tools, and AI systems used in border and migration management. Non-EU providers placing systems on the EU market through an authorised representative face the same revised deadlines.
Chapter V GPAI model obligations are unaffected by the AI Omnibus and continue to apply from 2 August 2026. The Commission delayed the high-risk rules primarily because harmonised standards, on which conformity assessments rely, were not ready by the original deadline. Whether those standards will be finalised before December 2027 is uncertain; several standardisation mandates under the AI Act remain in progress.
Licentium advises AI developers, deployers, and operators on EU AI Act compliance, including risk classification and deadline mapping against the revised AI Omnibus schedule. We can draw on a partner network for in-jurisdiction compliance support across EU member states. Work we undertake includes AI system risk tier classification, high-risk conformity assessment preparation, GPAI model documentation, technical documentation review, and advisory engagement with national AI supervisory authorities.
Source: EU, Digital Omnibus on AI (OJ L 2026/1744), entered into force 27 July 2026