REVISED 27 JUL 2026 · previous revision 6 JUL 2026
Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force today. It was published in the Official Journal on 24 July. (ELI: reg/2026/1744/oj), not against commentary. What changed in this revision →
The AI Act's high-risk rules moved to December 2027 - but the transparency rules didn't.
The Omnibus defers the high-risk obligations of Chapter III (the recruitment, credit-scoring and education tools you read about) to 2 December 2027 (Annex III) and 2 August 2028 (Annex I embedded systems). Those dates are now fixed and unconditional: the 'readiness-assessment trigger' from the Commission's November proposal did not survive into the final text (Art. 1(40), rewriting Art. 113 AI Act).
What it did not touch: Article 50. Chatbot disclosure, synthetic-content marking, deepfake and AI-text labelling, emotion-recognition notices. Of the 43 amendment points in the Omnibus, exactly one concerns Article 50, a procedural change to the codes-of-practice mechanism in 50(7). Paragraphs (1)–(6), the actual duties, are word-for-word unamended. They apply from 2 August 2026. That is this coming Sunday.
Download the free deadline map (PDF) Get the compliance pack: €99
The deadline ledger
| Date | What applies | Status |
|---|---|---|
| 2 AUG 2026 | Article 50 transparency duties. Disclose AI chatbots, mark synthetic content, label deepfakes and public-interest AI text, notify on emotion recognition. Fines for infringement up to €15 m or 3% of worldwide turnover (Art. 99(4)). Systems placed on the market from this date should comply from day one. | Not delayed |
| 2 DEC 2026 | Two unrelated obligations share this date. (1) Generative systems already on the market before 2 Aug 2026 must meet the Art. 50(2) machine-readable marking duty by now: a four-month transition, new Art. 111(4). (2) The new Article 5 prohibitions on AI generating non-consensual intimate material and CSAM apply, in the €35 m / 7% tier (Art. 113(3)(a) as amended). | New |
| 2 DEC 2027 | High-risk obligations, Annex III. Standalone systems: recruitment, credit, education, critical infrastructure and the rest. This is the part that moved (Art. 113(3)(c)(i)). | Deferred |
| 2 AUG 2028 | High-risk obligations, Annex I. AI embedded in regulated products, medical devices, vehicles, machinery (Art. 113(3)(c)(ii)). | Deferred |
| 2 AUG 2030 | Backstop for legacy systems in public use. High-risk systems placed on the market before the dates above stay out of scope unless significantly redesigned, but systems used by public authorities must comply by 2030 regardless (Art. 111(2) as amended). | Backstop |
Secondary dates (sandboxes 2027, notified-body designation Jan 2028, Commission guidance deadlines) are on the full map.
The Transparency Compliance Pack
A law-firm client alerts tell you the deadline exists and stop there. Counsel starts at five figures. This pack sits in between: seven plain-language guides plus a working register. Enough to scope your systems, deploy the notices, and evidence the work, adaptable in an afternoon - all referenced to the article level.
- Deadline map: the ledger above, one page, with full citations. For your leadership.
- Scoping decision tree: five questions that map each system to its exact obligations.
- Disclosure templates ×5: chatbot, deepfake, AI text, emotion recognition, biometric categorisation, each with a deployment checklist.
- AI inventory register (Excel): computes each system's duties and deadlines from its classification. Updated for the Omnibus, including the machinery reclassification.
- Marking & watermarking checklist: engineering-facing plan for Art. 50(2), including the 2 December legacy deadline.
- Prohibitions brief: the new Art. 5 bans (NCII, CSAM): scope, the provider/deployer split, the safeguards test.
- Leadership briefing: a pre-written memo: what changed, our exposure, our plan.
Buyers receive updates free through 2 December 2026. The Omnibus revision is the first of those updates, if you bought before 24 July, it is already in your library.
Licences
| Licence | Covers | Price | |
|---|---|---|---|
| Solo | All seven guides + register, single-company use, updates through 2 Dec 2026 | €99 | Buy |
| Consultant / Agency | Same contents, unlimited client engagements, reusable master register | €299 | Buy |
Not sure yet? Start with the free deadline map; it is the same table your leadership will ask for, and it will tell you whether the rest of the pack is worth €99 to you.
Compliance notes
- Is the EU AI Act delayed? Now a settled question.
- The Article 50 checklist
- The marking deadline, for the people who have to build it
Changelog
- 27 JUL 2026
- Full revision for Regulation (EU) 2026/1744 (in force this date). The deadline roadmap was re-verified against the OJ text; added the 2 Aug 2028 and 2 Aug 2030 rows; corrected the 2 Dec 2026 row to reflect both obligations sharing that date. Noted the Art. 50(7) procedural amendment: the only Omnibus change to Article 50. Register logic updated for the machinery move from Annex I Section A to Section B (Art. 1(41)). Market copy now says “guides”; “edition” is retained only as internal version numbering. Launch pricing ended (Solo €79 → €99, as scheduled 19 Jul, applied late, our mistake).
- 6 JUL 2026
- First publication. Guide No. 1 (EU AI Act Transparency Compliance Pack), free deadline map, three compliance notes.
About Statute Press
Statute Press publishes plain-language compliance guides for regulated deadlines. It produces actionable, working documents that give you more Thank reading a client alert and is more afforable than engaging counsel. Guides are verified against the primary sources on EUR-Lex, revised when the law moves, and every revision is dated and logged above.
How this is made
Drafts are produced with AI assistance. Every regulatory claim is then verified against the primary text on EUR-Lex before publication, and everything is edited under the responsibility of a practitioner with more than fifteen years in technology governance and regulation.