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Independent European Publication AI Act Operator Desk · Regulation 2024/1689 Monday, 17 August 2026
Agent Liability AI Act Operator Desk
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The Digital Omnibus Tracker

The Digital Omnibus on AI entered into force on 27 July 2026, six days before the original high-risk deadline. Annex III high-risk obligations now apply from 2 December 2027 and Annex I from 2 August 2028. This page records what moved, what did not, and what binds a deployer today. The legislative passage is closed and is kept below as the record.

Editorial notice. Every date on this page was re-verified on 17 August 2026 against the European Commission and the Council of the EU. Where a detail could not be read at an institutional source in that pass, the row says so rather than guessing. No carrier or vendor pays for placement on this tracker. See the methodology section below.
Current legislative stage
In force since 27 July 2026
Adopted
Days until Annex III applies
--
2 December 2027. Stand-alone high-risk AI systems.
Days until Annex I applies
--
2 August 2028. High-risk AI embedded in products.
Already in application
Art. 4, 5, 50, 99
AI literacy and prohibitions since 2 February 2025, GPAI since 2 August 2025, transparency and the penalty regime since 2 August 2026. None of these moved.

Legislative stages

The Omnibus followed the ordinary legislative procedure under Article 294 TFEU. Six stages, from the Commission proposal on 19 November 2025 to entry into force on 27 July 2026. This section is now the record of a closed file.

Done
Commission proposal
19 Nov 2025
Done
Council and Parliament positions
Spring 2026
Done
Political agreement
7 May 2026
Done
Parliament plenary vote
June 2026
Done
Council final adoption
29 Jun 2026
Done
Entry into force
27 Jul 2026
Stage 1 Done Commission proposal
19 November 2025

The European Commission presented COM(2025) 836, the Digital Omnibus on AI, a targeted amendment to Regulation (EU) 2024/1689. It proposed linking the application of the high-risk rules to the availability of harmonised standards and supporting tools, with a backstop of 2 December 2027 for stand-alone high-risk AI systems and 2 August 2028 for high-risk AI embedded in products. It travelled alongside COM(2025) 834, the broader Digital Omnibus touching the GDPR, the Data Act and NIS 2.

Stage 2 Done Council and Parliament negotiating positions
Spring 2026. Exact dates not confirmed at an institutional source in this pass.

The Council adopted a general approach and the European Parliament adopted a negotiating mandate on the basis of a joint IMCO and LIBE committee position. Both broadly accepted a deferral of the stand-alone high-risk obligations. We previously published specific committee and plenary dates for this stage. They could not be confirmed against a Council or Parliament document on 17 August 2026 and have been withdrawn rather than restated.

Stage 3 Done Political agreement
7 May 2026

Council and Parliament negotiators reached a provisional political agreement. The open question through the negotiation had been whether the new dates would be fixed or conditional on standards being ready. The co-legislators settled it by fixing them: 2 December 2027 and 2 August 2028, not "the later of these dates or the arrival of standards".

Stage 4 Done European Parliament plenary vote
June 2026

The Parliament approved the agreed text in plenary, together with the new prohibition on AI systems that generate child sexual abuse material or that depict an identifiable person's intimate parts without consent. Systems already on the market have until 2 December 2026 to comply with that prohibition.

Source: European Parliament press release. Verified 17 August 2026.
Stage 5 Done Council final adoption
29 June 2026

The Council gave final approval to the regulation simplifying the implementation of the harmonised rules on artificial intelligence. This was the last legislative act required before publication in the Official Journal.

Stage 6 Done Official Journal publication and entry into force
27 July 2026

The amending act is Regulation (EU) 2026/1744, published at OJ L, 2026/1744 on 24 July 2026 and in force on the third day after publication, 27 July 2026, six days before the original 2 August 2026 high-risk deadline. Anyone who planned on the original date being reached is not in breach; the obligations simply have not started. Anyone who stood down a compliance programme on the assumption of an 18 month reprieve should read the matrix below, because four sets of duties were never in scope of the deferral.

Source: European Commission, AI Omnibus enters into force. Verified 17 August 2026.

Provision-by-provision matrix

Each row shows the date the AI Act originally set, the date that now applies after the Omnibus, and how the provision came out. Colour coding: amber for moved, green for unchanged, grey where a detail could not be confirmed at an institutional source. Click any column header to sort. Use the filter buttons to narrow the view.

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

What applies right now, on 17 August 2026

The deferral moved two things: Annex III and Annex I. Everything below was outside its scope and is in application today, enforceable today. This is the list an operator most often gets wrong, because the headline said the AI Act was delayed by 18 months and it was not: one part of it was.

  • Article 5 prohibitions. The prohibited AI practices have applied since 2 February 2025 and were untouched by the deferral. Enforcement of them commenced on 2 August 2026. A system using a prohibited practice must cease. Source: Regulation (EU) 2024/1689, Article 5 and Article 113(1)
  • Article 50(1) chatbot disclosure. A deployer of an AI system that interacts with a natural person must tell that person they are dealing with an AI, clearly and in time for it to matter. Not deferred. In application since 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(1)
  • Article 50(3) emotion recognition and biometric categorisation disclosure. A deployer of a system that infers emotion or categorises a person biometrically must inform the people exposed to it. Not deferred. In application since 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(3)
  • Article 50(4) deepfake labelling. Anyone using AI to generate or manipulate image, audio or video that constitutes a deepfake must disclose it clearly and visibly. Not deferred. In application since 2 August 2026. Source: Regulation (EU) 2024/1689, Article 50(4)
  • Article 50(2) machine-readable marking, transitional period ending. A provider of a synthetic content system already on the market before 2 August 2026 has until 2 December 2026 to meet the machine-readable marking requirement. That is the next live date on this page, and it is 15 weeks away. Source: EC AI Act Service Desk implementation timeline. Verified 17 August 2026.
  • The new prohibition on non-consensual intimate imagery and CSAM generation. Added by the Omnibus, not removed by it. Systems already on the market have until 2 December 2026 to comply. Source: EC AI Act Service Desk implementation timeline. Verified 17 August 2026.
  • GPAI obligations, Articles 53 and 55. General-purpose AI model transparency, copyright policy and systemic-risk requirements have applied since 2 August 2025. Not deferred. Enforcement commenced on 2 August 2026. Source: Regulation (EU) 2024/1689, Articles 53, 55 and 113(2)
  • Article 4 AI literacy, in amended form. Still an obligation on providers and deployers, but with no mandated level. For a deployer of a high-risk system, the duty to train staff so that human oversight is real remains in place. Enforcement commenced on 2 August 2026 and sits with national market surveillance authorities. Source: EC AI literacy questions and answers. Verified 17 August 2026.
  • Article 99 penalties. The penalty regime applies from 2 August 2026, in respect of obligations that are themselves in application. Everything in this list is enforceable now. Annex III duties are not, until 2 December 2027. Source: Regulation (EU) 2024/1689, Article 99 and Article 113(3)

The dates that are still ahead

The legislative watch is over. What replaces it is a compliance calendar. Every date below is set by the AI Act as amended, verified against the Commission's own implementation timeline on 17 August 2026.

Date
What happens
Who it lands on
2 Dec 2026
Article 50(2) transitional period endsProviders of synthetic content systems already on the market before 2 August 2026 must meet the machine-readable marking requirement.
Anyone shipping a generative image, audio or video product in the EU. This is the nearest deadline on the page.
2 Dec 2026
New prohibition takes effect for existing systemsAI systems generating CSAM, or images, video or audio depicting an identifiable person's intimate parts without consent, must have been brought into line.
Providers of image and video generation systems, and any platform hosting them.
2 Aug 2027
National AI regulatory sandboxes operationalEach Member State must have at least one AI regulatory sandbox running.
Member States. For a deployer it is the practical signal of when national authorities intend to be ready.
2 Dec 2027
Annex III high-risk obligations applyStand-alone high-risk systems: risk management, data governance, technical documentation, logging, human oversight, accuracy and robustness, the Article 26 deployer file and the Article 27 FRIA.
Deployers and providers of employment, credit, insurance pricing, education, essential services, law enforcement and migration systems.
2 Aug 2028
Annex I high-risk obligations applyHigh-risk AI embedded in products already covered by EU harmonisation legislation.
Manufacturers of medical devices, machinery, lifts, toys and the rest of the Annex I product list, and their notified bodies.

A note on the gap. The distance between now and 2 December 2027 is 16 months, and the honest reading of that is not that the work went away. Harmonised standards are still not published, and the deferral exists because they are not. An operator who uses the 16 months to build the operator file against the current text will be ready. An operator who waits for the standards will be doing the work in the last quarter of 2027 alongside everyone else.

Editorial methodology

How this tracker is maintained, sourced, and updated.

Update cadence

Re-verified at source, ad hoc on material developments

Every date on this page was read against the European Commission and the Council of the EU on 17 August 2026. A tracker that is not re-read is a liability, and this one had been running on April 2026 facts. Any Official Journal entry, Commission implementation update or Member State designation triggers an ad hoc pass. The date below is the last verification, not the last text edit.

Sources monitored

Institutional sources only

  • EC AI Act Service Desk implementation timeline
  • European Commission, Shaping Europe's digital future
  • Council of the EU press releases
  • European Parliament press releases and Legislative Train
  • EUR-Lex and the Official Journal
  • Member State ministries, regulators and official gazettes

Law firm trackers and news reporting are used to find a document. They are never used to confirm one. Neither is a search engine summary, which in this subject area now reflects secondary commentary back as if it were the source.

Verification standard

Read at the issuing body, or marked as unread

Every date on this page was read on the website of the institution that owns it. Where we could not do that in the 17 August 2026 pass, the row says so in plain words and does not offer a number. Two rows say it: the Council and Parliament position dates in the passage record, and the amended Article 71 registration mechanics. We would rather show a gap than fill one.

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 17 August 2026
Next scheduled review 17 September 2026, then monthly
Next binding date Article 50(2) marking, 2 December 2026
Licence CC BY 4.0

Read the full Omnibus Master Brief

What the amendment actually changed, what it left alone, and what a deployer should be doing in the 16 months before Annex III applies.