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Independent European Publication AI Act Operator Desk · Regulation 2024/1689 Saturday, 25 April 2026
Agent Liability AI Act Operator Desk
Live Tracker ยท Updated 25 April 2026

The Digital Omnibus Tracker

The EU Omnibus Simplification Package proposes material amendments to the AI Act, including an 18-month delay to the Annex III high-risk obligations. This page tracks every legislative stage in real time, maps the proposed changes provision by provision, and identifies what remains binding on 2 August 2026 regardless of the Omnibus outcome. Bookmark it. Check it weekly.

Editorial notice. Data on this page is updated weekly at minimum and ad hoc on material developments. Where a figure is unverified we mark it explicitly. No carrier or vendor pays for placement on this tracker. See the methodology section below.
Current legislative stage
Omnibus is in Trilogue
Active Negotiations
Days until estimated adoption
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Target: 31 July 2026 (midpoint estimate only, not an official date)
Days until 2 August 2026
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Current binding deadline for Annex III high-risk AI obligations
Proposed new Annex III date
2 Dec 2027
Commission proposal; Parliament and Council positions differ. Not yet agreed.

Legislative stages

The Omnibus follows the standard co-decision procedure (ordinary legislative procedure) under Article 294 TFEU. Seven stages from Commission proposal to Official Journal publication.

Done
Commission proposal
26 Nov 2025
Done
Council general approach
Pending verification
Done
Parliament committee (IMCO + LIBE)
Late March 2026
Done
Parliament plenary mandate
Late March 2026
Active
Trilogue negotiations
Started April 2026
Pending
Political agreement
Expected Apr / May 2026
Pending
Formal adoption + OJ
Expected July 2026
Stage 1 Done Commission proposal
26 November 2025

The European Commission published COM(2025) 529, the Omnibus Simplification Package. For the AI Act, the package proposed moving the Annex III high-risk deadline from 2 August 2026 to 2 December 2027 and narrowing several Annex III categories. The Commission cited disproportionate compliance costs for SMEs as the rationale.

Stage 2 Done Council general approach
Pending verification of exact date

The Council of the EU adopted a general approach on the Omnibus. The Council broadly supported the Commission's proposed delay to Annex III obligations. Exact adoption date and full Council position text pending verification against Council press releases.

Stage 3 Done Parliament committee position
Late March 2026 (IMCO + LIBE joint committee)

The IMCO and LIBE committees of the European Parliament adopted a joint position on the Omnibus AI Act provisions. The committee position accepted the delay to Annex III but sought to preserve the FRIA obligation timeline and introduced amendments to the Article 50 machine-readable marking provisions.

Stage 4 Done Parliament plenary mandate
Late March 2026

The European Parliament plenary voted to grant a negotiating mandate based on the IMCO/LIBE committee position. This authorises MEP negotiators to enter trilogue with the Council. The Parliament's mandate represents its opening position for trilogue; the final text may differ materially.

Stage 5 Active Trilogue negotiations
First meeting: April 2026. Next scheduled: 28 April 2026

Trilogue is the informal inter-institutional negotiation between Parliament negotiators, Council Presidency, and Commission representatives. Key open issues include: the final Annex III deadline date, the scope of Annex III category narrowing, treatment of Article 27 FRIA obligations, and the Article 50 machine-readable marking grace period. Trilogue meetings are not publicly broadcast; outcomes reported via institutional press releases.

Stage 6 Pending Political agreement
Expected late April or May 2026

A political agreement is reached when negotiators from all three institutions agree on final text. This typically triggers a joint press release from Council Presidency, Parliament rapporteurs, and Commission. The text then goes to legal-linguistic finalisation before formal adoption. The political agreement is the definitive signal that a specific deadline date is locked.

Source: pending. Monitor Council press releases
Stage 7 Pending Formal adoption + Official Journal
Expected July 2026

After legal-linguistic finalisation, the Council and Parliament formally adopt the agreed text through written procedure. The regulation is then published in the Official Journal of the European Union. Entry into force is typically 20 days after OJ publication. For any Annex III delay to apply before 2 August 2026, formal adoption must precede that date.

Source: pending. Monitor EUR-Lex Official Journal

Provision-by-provision matrix

Each row shows the original AI Act date, the proposed new date, and the current status across the three institutions. Colour coding: amber for delayed, green for unchanged, grey for contested or unclear. Click any column header to sort. Use the filter buttons to narrow the view.

Show:
Provision Original date Proposed new date Status Council position Parliament position Trilogue Notes Source

What remains mandatory on 2 August 2026

Even if the Omnibus passes in full and is formally adopted before 2 August 2026, the following obligations bind on that date regardless. These are either (a) unchanged by the Omnibus proposal or (b) already in force. Plan your compliance programme around this list.

  • Article 5 prohibitions. All eight prohibited AI practices are already in force since 2 February 2025 and are not touched by the Omnibus. Any system using prohibited practices must cease immediately. Source: Regulation (EU) 2024/1689, Article 5 and Article 113(1)
  • GPAI Articles 53 and 55. General-purpose AI model obligations (transparency, copyright policy, systemic-risk assessment for frontier models) have applied since 2 August 2025. Not affected by the Omnibus. Source: Regulation (EU) 2024/1689, Articles 53, 55, and 113(2)
  • Article 50(1) chatbot disclosure. Deployers of AI systems that interact with natural persons in real time must inform those persons they are interacting with an AI, clearly and in a timely manner. Unchanged by the Omnibus. Effective 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(1)
  • Article 50(3) emotion recognition disclosure. Deployers of AI systems that perform emotion recognition or biometric categorisation must inform natural persons accordingly. Unchanged by the Omnibus. Effective 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(3)
  • Article 50(4) deepfake labelling. Any person who uses AI to generate or manipulate image, audio, or video content constituting a deepfake must disclose this in a clear and visible manner. Unchanged by the Omnibus. Effective 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(4)
  • Article 99 penalty regime. The enforcement architecture under Article 99 applies from 2 August 2026. Member State supervisory authorities will be empowered to investigate and impose penalties on deployers in breach of applicable obligations from that date. Source: Regulation (EU) 2024/1689, Article 99 and Article 113(3)
  • Article 26 deployer obligations (for systems not delayed). All deployer duties under Article 26 apply to high-risk AI systems not covered by an Omnibus delay. This includes the technical and organisational measures, human oversight staffing, and the incident reporting and logging duties. Source: Regulation (EU) 2024/1689, Article 26 and Article 113(3)

The 90-Day Omnibus Watch calendar

Week-by-week expected events from 25 April to 25 July 2026. Monitor these dates. Outcomes from each event may change the binding position materially.

Week of
Expected event
What to monitor
28 Apr 2026
Second trilogue meetingNegotiations continue on Annex III scope and deadline date. First substantive exchange on contested provisions.
Council Presidency press release. Watch for any leaked position papers. Council press
5 May 2026
Trilogue: expected third meetingPending verification. Article 27 FRIA timeline and Article 50(2) machine-readable marking likely on the table.
EP rapporteur statements. IMCO/LIBE committee notices. IMCO committee
12 May 2026
Trilogue: possible fourth meetingPending verification. If political agreement is close, an additional meeting may be scheduled at short notice.
Institutional social media for unscheduled meeting announcements. Law firm tracker updates.
19 May 2026
Political agreement window opensBased on current pace, a political agreement in the week of 19 May is plausible if negotiations advance on schedule.
Joint institutional press release is the definitive signal. Watch EUR-Lex for formal text. EUR-Lex
26 May 2026
Political agreement: extended windowIf May 19 window closes without agreement, negotiations extend. A delay past end of May raises risk that formal adoption may not precede 2 August 2026.
If no agreement by 31 May, begin planning for 2 August 2026 as a hard deadline. Inform compliance teams.
2 Jun 2026
Legal-linguistic finalisation beginsAfter political agreement, the text goes to legal-linguistic review in all 24 EU languages. This takes 4-8 weeks typically.
No public milestones during this phase. Monitor for any formal Council or EP adoption agenda items.
16 Jun 2026
Formal adoption preparationCouncil written procedure and Parliament plenary adoption vote may be scheduled for late June or early July to allow OJ publication before 2 August.
Council COREPER agenda items. EP plenary schedule. EP Plenary
30 Jun 2026
Critical window: formal adoption must occur by late JuneFor the regulation to enter into force before 2 August 2026 (standard 20-day period after OJ publication), formal adoption must complete by approximately 12 July.
If no adoption vote by 30 June, the 2 August deadline will bind. Begin contingency compliance measures. EUR-Lex OJ
7 Jul 2026
OJ publication window (if adopted)If formally adopted in the week of 30 June, OJ publication could occur in this window. The regulation enters into force 20 days later.
EUR-Lex Official Journal daily editions. Confirm entry into force date.
14 Jul 2026
Last viable adoption dateThis is the final week in which formal adoption and OJ publication could realistically occur to allow 20 days before 2 August. After this point, the original Annex III deadline applies.
If no OJ publication by 13 July 2026, Annex III obligations bind on 2 August 2026. Full compliance required.
21 Jul 2026
Final preparation weekRegardless of Omnibus status, organisations deploying high-risk AI systems should have completed their operator file, FRIA (where applicable), and human oversight documentation.
Internal audit of operator file. Legal sign-off on compliance documentation. Final readiness check.
2 Aug 2026
Deadline dayAnnex III high-risk obligations bind unless the Omnibus has been formally adopted and entered into force with a later date. Article 50 transparency obligations bind regardless.
Deployment of any Annex III system without a compliant operator file creates enforcement exposure from this date. 100-day checklist

Editorial methodology

How this tracker is maintained, sourced, and updated.

Update cadence

Weekly review, ad hoc on material developments

This tracker is reviewed every week at minimum. Any institutional press release, Official Journal entry, or verified trilogue outcome triggers an immediate ad hoc update. The "Updated" timestamp reflects the last editorial review, not just the last text change.

Sources monitored

Primary institutional and specialist sources only

  • EUR-Lex legislative train and Official Journal
  • Council of the EU press releases and meeting agendas
  • European Parliament IMCO and LIBE committee notices
  • EP Legislative Train (Sherpas updates)
  • AI Office official communications
  • European Commission Better Regulation portal
  • Selected law firm legislative trackers (Bird and Bird, Linklaters, Allen Overy)
Verification standard

Primary sources only. Unverified items marked.

Every date and position cited on this page is sourced from primary institutional documents where possible. Where we cannot verify against primary text, cells are marked "Pending verification" and linked to the relevant institutional page. We do not infer dates from secondary reporting alone.

Editorial firewall

No carrier or vendor pays for tracker visibility

No insurance carrier, AI vendor, law firm, or other commercial entity pays for inclusion, prioritisation, or framing on this tracker. Coverage decisions are made solely by the editorial team on the basis of legal materiality. This tracker is published under a CC BY 4.0 licence. You may reproduce it with attribution.

Last updated 25 April 2026
Next scheduled review 30 April 2026
After the 28 April trilogue Ad hoc update if material outcome
Licence CC BY 4.0

Read the full Omnibus Master Brief

Detailed analysis of every proposed change, the political dynamics, and what operators should do right now.