Nornic Register · Living document
“The EU AI Act's high-risk obligations land in August 2026.”
This was correct until the Digital Omnibus deferred the high-risk deadlines. It is now settled law rather than a proposal — the Omnibus entered into force on 27 July 2026 — and a large amount of live sales material is simply out of date.
The source
- Study
- Digital Omnibus amendments to Regulation (EU) 2024/1689
- Publisher
- European Parliament and Council
- Publication type
- Primary legislation
- Sample
- Not applicable — statutory instrument
- Fieldwork
- Parliament endorsement 16 June 2026; Council green light 29 June 2026; entered into force 27 July 2026
- Funding & conflicts
- Not applicable
- Verified on
- 2026-08-13
The arithmetic
Annex III stand-alone high-risk obligations moved from 2 August 2026 to 2 December 2027.
Annex I obligations — AI embedded in already-regulated products — moved from 2 August 2027 to 2 August 2028.
What did NOT move: Article 50 transparency obligations, including disclosing to a person that they are interacting with an AI system, marking synthetic output in a machine-readable format, and disclosing deepfakes. Those became applicable on 2 August 2026 and are live now.
The one narrow exception, which almost no guidance mentions: providers of systems already on the market before 2 August 2026 have until 2 December 2026 to implement the technical marking required by Article 50(2). That is the nearest real deadline in this entry, and it is the one nobody is selling.
Also unchanged: prohibitions and AI-literacy provisions have applied since 2 February 2025, and the GPAI, governance and penalties chapters since 2 August 2025. The Omnibus does simplify the AI-literacy duty, giving the Commission and member states a larger role in promoting it; the obligation itself was not deferred.
The practical effect is not "you have longer". It is that the deadline that applies to you now depends on which annex your system falls under, and most published guidance predates the change.
What would change this verdict
Further amendment, or a member-state implementation that pulls a national deadline earlier than the Union timetable. Both are checkable against primary sources.
Sources