- Read at source on 24 August 2026, the AI Act Service Desk pages for Articles 5, 6, 50 and 111 each carry a notice: "This provision has been amended by the Digital Omnibus on AI. The text displayed on this page has not yet been updated to reflect those amendments." The Article 113 page carries the same notice naming the proposal.
- The Article 26 page carries no notice at all. Absence of a banner is not a statement that the text is current, and a reader cannot tell from the page which it is.
- Article 113 as displayed still reads that the Regulation applies from 2 August 2026, with Article 6(1) from 2 August 2027. The timeline page on the same domain gives 2 December 2027 and 2 August 2028.
- Article 111 as displayed shows three numbered paragraphs. The amending Regulation inserted a fourth, which is in the Official Journal text and is not on the page.
- For operative wording, read the Official Journal. For the calendar, read the timeline page. For anything going into a policy or a board paper, record the URL and the date you read it.
- The largest exposure is not a lawyer misreading a page. It is a machine reader extracting article text without the banner, and a quotation copied into an internal document that will outlive the page it came from.
What is actually on the pages
This desk re-read six provisions at the Commission's AI Act Service Desk on 24 August 2026. What follows is what those pages served on that date. It is stated with the date attached because the whole point of the article is that these pages are being changed, which means anything written about them without a timestamp is worthless within weeks, including this.
Five of the six carried an amendment notice. On the Article 5, Article 6, Article 50 and Article 111 pages the notice read, word for word:
The Article 113 page carried the same notice in a slightly different form, naming the Digital Omnibus on AI Regulation Proposal rather than the Digital Omnibus on AI. The wording difference is not significant in itself and is recorded because it is what was there.
The Article 26 page carried no notice of any kind. That is the observation with the most operational weight in this article, and it is treated separately below.
None of this is a failure on the Commission's part. Publishing the pre-amendment text under an explicit warning is a defensible interim position, and it is considerably better than silently serving text that has changed. The problem this article is concerned with is what happens downstream of that choice, in compliance functions, in policy documents and in the machine readers that now sit between most people and most regulatory text.
The date conflict, precisely
Article 113 is the application provision. It is the article a compliance function opens when building a calendar. As displayed on 24 August 2026 it reads that the Regulation enters into force on the twentieth day following publication in the Official Journal, that it shall apply from 2 August 2026, and then sets out three exceptions: Chapters I and II from 2 February 2025; Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 from 2 August 2025, with the exception of Article 101; and Article 6(1) and the corresponding obligations from 2 August 2027.
Now read the implementation timeline page on the same domain, which is current. It gives 2 August 2026 for the majority of the rules and the start of enforcement, 2 December 2026 for the new prohibitions and the Article 50(2) transition, 2 August 2027 for Member State AI regulatory sandboxes, 2 December 2027 for Annex III high-risk systems, and 2 August 2028 for high-risk AI embedded in regulated products under Annex I.
| Question | Article page, as displayed 24 Aug 2026 | Timeline page, current |
|---|---|---|
| When do Annex I high-risk obligations apply? | Article 113: Article 6(1) and corresponding obligations from 2 August 2027 | 2 August 2028 |
| When do Annex III high-risk obligations apply? | Article 113: covered by the general 2 August 2026 application date | 2 December 2027 |
| What lands on 2 December 2026? | Not addressed on the Article 113 page | New prohibitions, and the Article 50(2) transition for systems already on the market |
| When must Member States have a sandbox? | Not addressed on the Article 113 page | 2 August 2027 |
A compliance calendar built from the left-hand column is wrong in two directions at once. It pulls Annex III forward by sixteen months, which produces panic and wasted budget, and it pulls Annex I forward by a year, which produces the same. Nothing about the reader's behaviour was unreasonable. They opened the application article on the Commission's own service desk, which is exactly where a careful person would look.
The paragraph that is not on the page
Article 111 governs systems already on the market and general-purpose AI models already placed on the market. It is the provision that answers the most common question a deployer with an existing estate actually has, which is whether anything they are already running is caught.
As displayed on 24 August 2026, the page shows three numbered paragraphs. Paragraph 1 addresses AI systems that are components of the large-scale IT systems listed in Annex X, placed on the market before 2 August 2027, requiring compliance by 31 December 2030. Paragraph 2 provides that the Regulation applies to operators of other high-risk AI systems placed on the market or put into service before 2 August 2026 only if, as from that date, those systems are subject to significant changes in their design, with providers and deployers of high-risk systems intended for use by public authorities required to comply by 2 August 2030. Paragraph 3 gives providers of general-purpose AI models placed on the market before 2 August 2025 until 2 August 2027 to comply.
The amending Regulation inserted a fourth paragraph. Regulation (EU) 2026/1744 added Article 111(4), which gives providers of generative systems placed on the market before 2 August 2026 until 2 December 2026 to meet the Article 50(2) machine-readable marking obligation. That paragraph is in the Official Journal text of the amending Regulation. It is not on the Article 111 page, which is precisely what the notice at the top of that page is telling the reader.
There is a second and more consequential question that this desk is not going to answer, and the reason for not answering it is the point of the section. Paragraph 2 sets its legacy trigger at 2 August 2026, which was the original application date for standalone high-risk obligations. That date has moved to 2 December 2027. Whether the amending Regulation adjusted the reference in Article 111(2), and if so how, cannot be established from a page that states on its face that it has not been updated. It has to be read in the consolidated Official Journal text.
This is not a rhetorical caution. A guessed answer to that question determines whether an agent your organisation has been running since 2025 is inside or outside the high-risk regime, and it is exactly the class of question where a plausible answer assembled from summaries reads identically to a correct one.
The page with no banner
Article 26 is the deployer article. It is the most consulted provision on this site's traffic and almost certainly on the Service Desk's. On 24 August 2026 its page carried no amendment notice.
There are two possible reasons and a reader cannot distinguish them from the page. The first is that Article 26 was not amended by the Omnibus, in which case the displayed text is current and the absence of a banner is correct. The second is that the notice has been applied to some pages and not yet to others, in which case the absence of a banner carries no information at all.
The practical consequence is the same either way, and it is worth stating as a rule: the presence of the notice is informative, the absence of it is not. A reader can rely on a banner to know that a page is stale. A reader cannot rely on a missing banner to know that a page is current. That asymmetry removes the shortcut that would otherwise make this a minor formatting matter, because it means every article page has to be treated as potentially superseded regardless of what it displays.
Our own treatment of the provision, which is written against the obligation rather than transcribed from the page, is at the Article 26 deployer obligations guide.
Why this is worse for machines than for lawyers
A lawyer reading the Article 113 page will, on a good day, notice a grey box. Three downstream consumers of the same page will not.
Assistants and retrieval systems. The overwhelming majority of questions about the AI Act are now answered by a system that has read a page rather than by a person who has. A notice rendered as a styled box near the top of a document is presentational, and presentational elements are the first thing lost when a page is converted to plain text for extraction. The operative text survives the conversion. The warning about the operative text may not. That is a mechanism by which superseded dates propagate confidently, and it is not hypothetical: it is the ordinary behaviour of the pipeline.
Internal policy documents. Compliance functions quote article text into their own governance documents, and those documents persist. Wording copied today from an article page is superseded wording that will sit inside an evidence pack, be read by an auditor in 2027, and be taken as the organisation's understanding of its own obligations. Nobody will re-check the quotation, because it came from the Commission.
Downstream publication. Every guide, briefing note and vendor questionnaire built on these pages in the past few weeks inherits the same problem, and inherits it silently. The same applies to this network, which is why the sourcing discipline below is stated as a rule rather than left implicit. Our approach to it is set out at the Omnibus master brief, and the machine-readable half of the question is treated at agentcertified.eu, on certifying the knowledge base an agent reads from, where the same failure appears one layer down.
Five rules for citing the Act right now
None of these is difficult. They cost a few seconds each and they are the difference between a citation that can be checked in two years and one that cannot.
- Separate dates from wording. For the application calendar, cite the Commission's implementation timeline page, which is current. For operative text, cite the Official Journal. Do not take both from the same article page.
- Read the amending Regulation, not only the Act. Regulation (EU) 2024/1689 alone is no longer the law. It is the law as amended by Regulation (EU) 2026/1744, which entered into force on 27 July 2026. Anything quoting only the first is quoting a superseded instrument.
- Record the read date on every citation. A URL without a date cannot be verified later, because the page will have changed and there is no way to establish what it said when you read it. This applies with particular force to a domain that is mid-update.
- Treat a missing banner as unknown, not as current. Presence of the notice is informative. Absence of it is not.
- Do not resolve an open question from a summary. Where a provision's current wording matters to a classification decision, read it in the Official Journal or get counsel to. The Article 111(2) trigger date is the live example.
The wider point about official sources
Practitioners carry a working assumption that the risk of a wrong regulatory fact sits in secondary sources: trade press, vendor blogs, summaries, assistants. It mostly does. This is a case where the primary source was mid-amendment, said so clearly, and was still capable of producing a wrong compliance calendar in the hands of a careful reader who did everything right.
The lesson is not that official sources are unreliable. It is that "I read it on the Commission's website" is not by itself a complete provenance record. Which page, on which date, and does that page say anything about its own currency, are the three additional facts that make the citation load-bearing. They are cheap to record and impossible to reconstruct afterwards.
This desk will re-read these six pages and record any change. The state described here is the state on 24 August 2026 and should be re-checked before being relied on, which is the same instruction we would give about any page that carries a notice about itself.
Questions
Is the EU AI Act text on the Commission's AI Act Service Desk current?
Not on every article page, and the pages say so. Read on 24 August 2026, the pages for Articles 5, 6, 50 and 111 each carry a notice reading: "This provision has been amended by the Digital Omnibus on AI. The text displayed on this page has not yet been updated to reflect those amendments." The Article 113 page carries the same notice naming the proposal. The implementation timeline page on the same domain is current and reflects the post-Omnibus dates. The domain is reliable; the pages within it are not uniformly so, which is a more awkward problem than a site simply being out of date.
What is the practical date conflict this creates?
Article 113 as displayed reads that the Regulation applies from 2 August 2026, with Chapters I and II from 2 February 2025, a set of provisions from 2 August 2025 with the exception of Article 101, and Article 6(1) with its corresponding obligations from 2 August 2027. The timeline page on the same domain gives 2 December 2027 for Annex III standalone high-risk systems and 2 August 2028 for Annex I systems embedded in regulated products. Two readers using two official pages produce two different calendars, and only one page warns them.
Does Article 26 carry the amendment notice?
No. Read on 24 August 2026 the Article 26 page carried no notice of any kind. That is the most operationally important observation here, because Article 26 is the most consulted provision for deployers and because the absence of a banner is ambiguous. It may mean the provision was not amended, or it may mean the notice has not been applied to that page. A reader cannot distinguish the two, and should not treat a missing banner as a positive statement that the text is current.
Where should a compliance function read the operative text instead?
For operative wording, the Official Journal text of Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, which entered into force on 27 July 2026. The Publications Office serves the official text by CELEX identifier, 32024R1689 and 32026R1744. For the application calendar, the Commission's implementation timeline page is current and is the right citation for dates. For anything going into a board paper, an evidence pack or a policy document, record the URL and the read date, because a quotation without one cannot be checked later.
Why does this matter more than it looks?
Three second-order effects. Machine readers: an assistant answering from an article page inherits pre-Omnibus text, and a presentational banner is the part most likely to be lost in text extraction. Quotation persistence: article text copied into an internal policy today is superseded wording that will sit in an evidence pack for years and be read as the organisation's understanding of the law. And the uneven application of the notice means its absence carries no information, which removes the shortcut that would make this minor.
Has Article 111(2) been changed by the Omnibus?
This desk is not going to state an answer, and the refusal is deliberate. Article 111(2) sets its legacy trigger at 2 August 2026, the original application date for standalone high-risk obligations, and that application date has moved to 2 December 2027. Whether the reference in 111(2) was adjusted cannot be established from a page that states on its face that it has not been updated. It has to be read in the consolidated Official Journal text, at CELEX 32026R1744. A guessed answer decides whether systems already running are inside or outside the high-risk regime, which is not a question to resolve from a summary.
Related analysis
- The Digital Omnibus in force: what changed for deployers. The master brief on what moved and what did not.
- What lands on 2 December 2026. The date cluster inside the deferral window.
- Article 99 penalties and fines. The ceilings, and which authority applies which.
- Member State implementation tracker. Where each of the 27 stands, verified at national sources.
- The Omnibus dates for non-EU operators. agentliability.co. The same calendar in the global register.
- The deadline moved. Do I still need cover? insureyouragent.com. The same question in the SME register.
Sources
- European Commission, AI Act Service Desk. Article pages for Article 5, Article 6, Article 26, Article 50, Article 111 and Article 113, all read 24 August 2026. Source for the amendment notice wording, for its presence on five of the six pages and its absence on Article 26, and for the article text quoted above as displayed on that date.
- European Commission, AI Act Service Desk. Timeline for implementation of the EU AI Act, read 24 August 2026. Source for the current application dates: 2 August 2026, 2 December 2026, 2 August 2027, 2 December 2027 and 2 August 2028.
- Regulation (EU) 2026/1744, the Digital Omnibus on AI, in force 27 July 2026. Annex III obligations from 2 December 2027, Annex I from 2 August 2028. It also inserted Article 111(4), giving providers of generative systems placed on the market before 2 August 2026 until 2 December 2026 to meet Article 50(2). European Commission, AI Omnibus enters into force. Official text served by the Publications Office at CELEX 32026R1744.
- Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence, OJ L, 12.7.2024. Official text served by the Publications Office at CELEX 32024R1689. Articles 5, 6, 26, 50, 99, 111 and 113 as referenced above.
- Directive (EU) 2024/2853 on liability for defective products, OJ L, 18.11.2024. National transposition deadline 9 December 2026. Not amended by the Digital Omnibus, and included here only because it is the other December 2026 date compliance calendars carry.