EU AI Act 'Digital Omnibus' in force: high-risk rules delayed to Dec 2027, GPAI enforcement starts Aug 2
The EU's Digital Omnibus on AI (Parliament vote 2026-06-16, Council adoption 06-29) entered into force on 2026-07-27, postponing Annex III high-risk obligations from 2026-08-02 to 2027-12-02 and embedded-product rules to 2028-08-02; on 2026-08-02 the AI Office's enforcement powers over general-purpose AI models (fines up to 3% of turnover) and Article 50 transparency duties took effect.
Key facts
- Political agreement 2026-05-06; EP approval 06-16; Council adoption 06-29; in force 07-27
- Annex III stand-alone high-risk: 2026-08-02 -> 2027-12-02; Annex I embedded products: 2027-08-02 -> 2028-08-02
- Article 50 transparency obligations stay on 2026-08-02; watermarking grace period to 2026-12-02 for systems already on market
- New Article 5 ban on AI generating non-consensual intimate imagery / CSAM (transition to 2026-12-02)
- From 2026-08-02 the AI Office can fine GPAI providers up to €15M or 3% of global turnover; prohibited practices up to €35M or 7%
- GPAI models placed on market before 2025-08-02 have until 2027-08-02 to comply
What happened
Facing unfinished harmonised standards and conformity-assessment infrastructure, the EU amended its AI Act before the major August 2026 milestone. High-risk obligations slipped ~16 months, but transparency rules and GPAI enforcement began on schedule.
Why it matters
The world's most comprehensive AI law is now enforceable against frontier model providers, while its heaviest obligations were delayed — a sign of the EU's shift toward competitiveness under pressure from industry and the US.
Changelog
- 2026-09-29: created
Sources (4)
- pressGibson Dunn: EU AI Act omnibus agreement
- pressUsercentrics: Digital Omnibus now in force
- officialEuropean Commission: enforcement framework of the AI Act
- pressWilson Sonsini: EU AI Act enforcement phase begins
id: 2026-07-27-eu-ai-act-digital-omnibus · updated 2026-09-29 · open in the interactive timeline