Digital Omnibus Postpones High-Risk Annex III to December 2027 — But Article 50 Is Live Now

Regulation (EU) 2026/1744 (the Digital Omnibus), which entered into force July 27, delayed the most significant high-risk AI compliance obligations under Annex III (recruitment, credit scoring, education, biometrics, law enforcement, justice) from August 2, 2026 to December 2, 2027, and deferred Annex I systems embedded in regulated products to August 2, 2028. The postponement reduced the compliance burden that had been expected to affect legal AI systems used in hiring and matter assignment workflows — but it did not move Article 50 transparency obligations, which went live August 2 as scheduled. For legal tech operators, the practical effect is that the most immediate obligations are disclosure and labeling (Article 50), not the full technical documentation and conformity assessment regime — but the clock on the latter is now running. Companies with six-to-twelve-month lead times for technical documentation and fundamental-rights impact assessments should have begun that preparation before the Digital Omnibus postponement, and should not use the delay as a reason to defer governance infrastructure work.