EU Digital Omnibus Defers AI Act High-Risk Obligations to December 2027

The European Parliament on June 16 adopted its plenary position on the Digital Omnibus on AI, provisionally deferring the AI Act's Annex III high-risk AI system obligations from August 2, 2026 to December 2, 2027, and Annex I embedded systems to August 2, 2028. The deferral follows the political agreement reached on May 7 and is not yet formally adopted — formal Council adoption and Official Journal publication are anticipated in July 2026. Until then, the August 2, 2026 deadline remains technically operative. AI Act Article 50 transparency obligations (AI disclosure, content marking) are unaffected and apply from August 2, 2026, with a grace period for generative AI systems already on market until December 2026. For in-house teams and outside counsel advising on AI governance, the deferral reduces immediate conformity assessment urgency — but the compliance build required for December 2027 is identical in scope, meaning firms should not treat the deferral as a reason to pause preparation.