Regulation (EU) 2026/1744, the Digital Omnibus on AI, amends the EU AI Act. For teams that ship AI features, three changes matter most.
High-risk duties moved
- Annex III high-risk duties now apply from 2 December 2027.
- Annex I embedded high-risk duties now apply from 2 August 2028.
Transparency did not move
Article 50 transparency duties apply from 2 August 2026, and the Article 50(2) marking duty for AI-generated content applies from 2 December 2026. A chatbot or content feature that is not high-risk can still be in scope today.
What to do with the extra time
Use it to build the habit, not to wait. Register your systems, record a risk class with its rationale, and start collecting evaluation results and approvals on every release. Evidence gathered over a year of releases is far stronger than a file assembled the month before a deadline.
This article is general information, not legal advice. Your counsel decides how the law applies to your systems.
