Regulation (EU) 2026/1744, the Digital Omnibus on Artificial Intelligence, was published in the Official Journal of the European Union on 24 July 2026 and entered into force on 27 July 2026. The regulation is final and binding in all EU member states. It constitutes the first substantive amendment to the AI Act, Regulation (EU) 2024/1689, and sits within a broader legislative package reducing compliance obligations across EU digital law.
The Omnibus amends the transition provisions of the AI Act. The compliance date for stand-alone high-risk AI systems listed in Annex III moves from 2 August 2026 to 2 December 2027. High-risk systems embedded as safety components in products covered by Annex I sectoral legislation move to 2 August 2028. Article 5 prohibitions on unacceptable-risk AI, Chapter V general-purpose AI model obligations, and Article 50 transparency duties keep their original 2 August 2026 application date.
Providers and deployers of Annex III systems in employment, recruitment, credit scoring, biometric categorisation, law enforcement, and critical infrastructure gain 16 additional months before conformity assessment, technical documentation, and EU AI database registration obligations apply. AI deployers using chatbot interfaces or synthetic image and audio generation tools remain subject to Article 50 disclosure duties from 2 August 2026 and must inform users when they interact with AI systems.
The extension does not alter obligations under parallel EU instruments including the GDPR, the revised Product Liability Directive, or sector-specific financial services rules that apply independently to AI-enabled products. Member state market surveillance authorities retain full competence over Article 5 prohibited practices from 2 August 2026. National regulators will need to distinguish between prohibited AI practices and high-risk obligations when opening cases under the two timetables now running concurrently.
Licentium advises clients on AI Act compliance positioning, including gap assessments, conformity documentation, and registration strategy under the amended timetable, and can refer matters to specialist counsel in EU member state jurisdictions. Work we undertake includes AI Act compliance strategy, high-risk system classification, Article 50 transparency implementation, GPAI model obligations, and national authority engagement.