AI Act: what was postponed, and what has applied since 2 August

What the Omnibus actually delayed

Regulation (EU) 2026/1744, the “Digital Omnibus on AI”, published in the Official Journal of the European Union on 24 July 2026 and in force from 27 July, is the first amendment to the AI Act. It pushes back substantive requirements for high-risk systems: to 2 December 2027 for standalone systems in Annex III (recruitment, education, credit scoring, biometrics, essential services…) and to 2 August 2028 for those embedded in regulated products (Annex I).

It also introduces reliefs for SMEs and small mid-cap companies: simplified technical documentation, proportionate quality requirements, and reduced fine caps.

What already applies

The most common confusion is hearing “the AI Act is postponed”. That is inaccurate. Still in force: prohibited practices and the requirement for AI literacy among staff (since 2 February 2025), obligations for general-purpose AI models (since 2 August 2025), and, since 2 August 2026, the transparency obligations of Article 50:

• inform people that they are interacting with an AI system, for example a chatbot;
• machine-readably mark synthetic content: text, image, audio, video;
• disclose deepfakes;
• inform people exposed to emotion recognition or biometric categorisation.

One calendar flexibility exists on this point: machine-readable marking for generative systems placed on the market before 2 August 2026 is required only from 2 December 2026. The EU penalty regime is active: depending on severity, up to €35 million or 7% of worldwide turnover, or €15 million or 3% in other cases.

For an organisation that uses AI without building it

If you deploy an assistant on your site, draft content with generative tools, or integrate AI into your processes, you are very likely a “deployer” under the text. First steps are straightforward:

1. 01Inventory AI uses, internal and customer-facing.
2. 02Display a clear notice on assistants and generated content.
3. 03Train teams: the AI literacy obligation was reframed as a duty of means, but it remains binding for every deployer.
4. 04Document where data goes: a model run locally greatly simplifies the answer.