The European legislator is planning adjustments to the AI Act. Following a provisional agreement between Parliament and the Council the so-called Digital Omnibus is primarily intended to postpone certain application deadlines without abandoning the risk-based core approach of the AI Act. An agreement on these changes has already been reached in the trilogue between the European Parliament, the Commission, and the Council of the European Union.
The focus is on high-risk AI systems. Under the agreement, the postponed obligations for these systems will no longer take effect on August 2, 2026: For standalone high-risk AI systems, they will apply only starting December 2, 2027, and for high-risk AI systems embedded in products, only starting August 2, 2028. This gives providers and operators more time to implement the requirements.
There will also be a transitional provision for labeling AI-generated content. For systems that were already placed on the market before August 2, 2026, the labeling requirement will be postponed until December 2, 2026.
At the same time, the agreement calls for explicitly prohibiting certain AI practices, in particular the generation of non-consensual intimate or sexual content (especially so-called “nudifier” apps) and child sexual abuse material.
The Council formally adopted the provisional agreement on June 30. The legislative act will be published shortly in the Official Journal of the EU and will enter into force on the third day following its publication. The legislature intends to have the amendments enter into force before August 2, 2026—the date on which the current rules for high-risk systems would take effect.
Organizations should not regard the additional implementation periods as a delay that eliminates the need for action. We recommend identifying existing and planned AI systems at an early stage, conducting the necessary risk assessment, and incorporating the required documentation and labeling requirements into project plans, among other measures.
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