The essentials
- Regulation (EU) 2026/1744, in force since 27 July 2026, postpones high-risk AI system obligations to 2 December 2027 (Annex III) and 2 August 2028 (Annex I).
- It does not postpone Article 50: since 2 August 2026, deployers must inform users of chatbots, label generated content, and disclose deepfakes.
- Next milestone: 2 December 2026, with machine-readable marking for generative systems already on the market and two new prohibitions.
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:
- 01Inventory AI uses, internal and customer-facing.
- 02Display a clear notice on assistants and generated content.
- 03Train teams: the AI literacy obligation was reframed as a duty of means, but it remains binding for every deployer.
- 04Document where data goes: a model run locally greatly simplifies the answer.
Sources
- AI Act : obligations en vigueur et reports de l’omnibus 2026/1744ActuIA
- Omnibus IA : le nouveau calendrier de l’AI Actdonneespersonnelles.fr
- Le Digital Omnibus est en vigueur : ce que le règlement (UE) 2026/1744 change dans l’AI ActSpicy Advisory · 28 July 2026
- AI Act : ce qui change vraiment pour les entreprises au 2 août 2026IT for Business
This note was drafted with AI tools from the cited sources, then reviewed and published under the responsibility of Jordan FOUASSIER, publication director. We summarise the facts and add our reading; source text and images are not reproduced. An error? Write to contact@aigyrosgroup.com.