EU AI Act Omnibus Defers High-Risk Deadlines — But August 2026 Transparency Obligations Stand
The EU institutions reached provisional political agreement on May 6–13 on the Digital Omnibus on AI, deferring the applicability of high-risk AI system obligations from August 2026 to December 2027 (Annex III systems, including recruitment and certain legal/law enforcement tools) and August 2028 (Annex I regulated products).
BY KM DESK · JUNE 1, 2026 · 1 MIN READ
The EU institutions reached provisional political agreement on May 6–13 on the Digital Omnibus on AI, deferring the applicability of high-risk AI system obligations from August 2026 to December 2027 (Annex III systems, including recruitment and certain legal/law enforcement tools) and August 2028 (Annex I regulated products). However, Article 50 transparency obligations — including the requirement to disclose to users when they are interacting with AI — remain scheduled for August 2, 2026. A four-month grace period for existing systems under the watermarking obligation (Article 50(2)) runs to December 2, 2026. Gibson Dunn's May 27 analysis notes that formal adoption and Official Journal publication are expected before August 2 and that businesses must continue preparing: the new dates only bind upon publication. For law firms deploying or advising on AI systems in the EU, August 2 is an active compliance date that KM and governance teams cannot treat as deferred.