Today, Regulation (EU) 2026/1744, commonly referred to as the AI Act Digital Omnibus, was published in the Official Journal of the European Union (L Series). The Regulation will enter into force on 27 July 2026, three days after its publication.
The publication marks the completion of the legislative process and provides legal certainty regarding the revised implementation timetable for the AI Act. While the Digital Omnibus does not alter the overall architecture or objectives of the AI Act, it introduces a number of targeted amendments intended to improve proportionality, simplify implementation and provide additional time for compliance with certain obligations.
For organisations developing, deploying or distributing AI systems in the European Union, this is the moment to revisit compliance programmes and update implementation roadmaps accordingly.
The AI Act’s Main Milestones
The Digital Omnibus confirms that the AI Act’s phased application will continue, albeit with several important adjustments.
2 August 2026
This remains the most significant compliance milestone.
From this date, most provisions of the AI Act become applicable, including:
- the transparency obligations under Article 50;
- the commencement of the enforcement and sanctions regime; and
- most of the Regulation’s remaining substantive obligations.
Despite the amendments introduced by the Digital Omnibus, the general application date of the AI Act therefore remains unchanged.
2 December 2026
Two important obligations apply from this date:
- the new prohibitions under Article 5 concerning non-consensual intimate material and child sexual abuse material; and
- the deadline for providers of generative AI systems already placed on the market to comply with the Article 50(2) marking requirements.
2 August 2027
Several institutional milestones become applicable, including:
- delegated acts concerning the equivalence clause;
- national AI regulatory sandboxes becoming operational; and
- Commission guidance on the interaction between the AI Act and EU harmonisation legislation.
2 September 2027
The European Commission must publish guidance on post-market monitoring.
2 December 2027
The obligations contained in Chapter III, Sections 1-3 begin to apply to high-risk AI systems classified under Article 6(2) and Annex III.
28 January 2028
Applications may be submitted for the designation of notified bodies.
2 August 2028
The requirements of Chapter III, Sections 1-3 become applicable to high-risk AI systems under Article 6(1) and Annex I.
2 August 2030
The deadline for AI systems intended to be used by public authorities remains unchanged.
What Should Organisations Do Now?
Publication of the Digital Omnibus should not be interpreted as a reason to delay AI compliance programmes. On the contrary, it provides greater certainty regarding the implementation timeline while confirming that the core obligations of the AI Act remain firmly in place.
Organisations should now:
- review AI governance programmes against the revised timetable;
- confirm which obligations become applicable on 2 August 2026;
- identify AI systems falling within the revised transitional regime;
- update internal compliance roadmaps and project plans; and
- monitor forthcoming Commission guidance and delegated acts that will further clarify implementation.
Final Thoughts
The Digital Omnibus is best understood as a targeted legislative refinement rather than a fundamental reform of the AI Act. It preserves the Regulation’s risk-based approach while adjusting certain deadlines and implementation mechanisms to facilitate a more proportionate transition.
With publication in the Official Journal, the debate has largely shifted from legislation to implementation. For organisations subject to the AI Act, the priority is no longer preparing for future regulation—it is preparing for compliance.
