Issues
Volume I · 2026The Digital Omnibus and What Still Binds in 2026
The Digital Omnibus proposes delaying Annex III high-risk obligations to December 2027 but has not been adopted. Article 5, Article 50, and GPAI obligations remain fixed for 2 August 2026. HSB, Armilla via Chaucer, and Testudo all moved on AI liability coverage in Q1. Italy enacted national implementing legislation in October 2025. Two US court decisions now sit in every underwriter's reference file.