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Provisional Digital Omnibus deal — high-risk deadlines shifted

On 7 May 2026, the Council of the EU and the European Parliament reached provisional political agreement on the Digital Omnibus on AI. Key shifts:

  • Annex III high-risk obligations: 2 August 2026 → 2 December 2027
  • Annex I product-embedded high-risk: 2 August 2027 → 2 August 2028
  • New Art. 5 prohibition on AI generating child sexual abuse material or non-consensual intimate imagery: 2 December 2026
  • Art. 50(2) machine-readable watermarking ONLY: 2 August 2026 → 2 December 2026
  • Member State AI sandboxes: 2 August 2026 → 2 August 2027

What is NOT delayed by the Omnibus — still live on the original dates:

  • Art. 4 AI literacy — in force since 2 February 2025 (all organisations)
  • Art. 5 existing prohibitions — in force since 2 February 2025
  • Chapter V GPAI obligations — in force since 2 August 2025
  • Art. 50 transparency duties (chatbot disclosure 50(1), emotion recognition / biometric categorisation 50(3), deepfake disclosure 50(4), public-interest disclosure 50(5)) — still 2 August 2026. Only the machine-readable watermarking limb (50(2)) was shifted.

If you deploy a chatbot, a deepfake-generation tool, an emotion-recognition system or a biometric categoriser — your 2 August 2026 deadline is unchanged, even if your underlying AI is "minimal risk".

The Omnibus agreement is provisional. Formal adoption by Council and Parliament is expected before 2 August 2026. If formal adoption fails, the original Regulation (EU) 2024/1689 dates apply across the board.

See regulatory updates for full source citations.

Annex III high-risk: provisionally 2 Dec 2027 — but most of Art. 50 transparency stays at 2 Aug 2026. If you deploy a chatbot, deepfake tool, emotion-recognition system or biometric categoriser — your 2 August 2026 deadline is unchanged. Art. 4 AI literacy and Art. 5 prohibitions are live today. Enterprise procurement teams are issuing AI vendor questionnaires now; notified body queues already span 9–24 months. 566 days to the Annex III headline date; the operational fix list is longer.

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