AI Omnibus in the Official Journal: Europe renegotiates the AI Act deadlines

Published in the Official Journal of the European Union on 24 July, Regulation (EU) 2026/1744 — known as the digital AI Omnibus — enters into force on 27 July, significantly reshaping the application timetable of the AI Act. Signed in Strasbourg by Roberta Metsola and Tadgh Byrne, the act revises the original calendar, which had set 2 August 2026 as the starting date for the heaviest obligations on high-risk systems. The legislative procedure, closed by the European Parliament's favourable vote in June and the Council's subsequent green light, moves compliance for Annex III systems to 2 December 2027 and for Annex I systems to 2 August 2028, changing the time horizon for companies in the sector.

While the high-risk deadlines loosen their grip, the regulation imposes strict requirements on synthetic content already in circulation. Providers of systems generating synthetic audio, image, video or text content placed on the market before 2 August 2026 will have to comply with the marking obligation in Article 50(2) by 2 December 2026. In parallel, Article 5 introduces new targeted prohibitions aimed specifically at the generation or manipulation of non-consensual intimate material and child sexual abuse material; the scope of this ban is limited to realistic depictions of intimate parts or sexually explicit acts, and it leaves out cases where intimate parts are not shown or are shown with freely given consent. These prohibitions apply from 2 December 2026.

On penalties and governance, the text introduces proportionality correctives: Member States must take into account the interests of SMEs, start-ups and small mid-cap companies; for the latter, the fine equals the lower of the two figures set out in paragraphs 4 and 5, the turnover percentage or the fixed amount. For high-risk systems intended for public authorities, providers and deployers have until 2 August 2030. In Italy, where supervision falls to the National Cybersecurity Agency and notification procedures to AgID, the operational details still have to be defined through the implementing decrees of Law 132/2025.

The simplification exercise promoted by the Commission thus looks like a recalibration of the balance between innovation and regulation: time is granted to the most complex infrastructure, while the net tightens around anomalies in generated content. The Article 50 transparency rules, by contrast, stay fixed at 2 August 2026 for systems placed on the market from that date, and the penalty framework is unchanged. The real challenge is no longer the entry-into-force date, but the ability of those involved to turn these new deadlines into technical compliance — a task made less immediate by the need to wait for further Commission guidance expected in 2027.

— Olya