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.

Get the compliance pack: €99 Download the free deadline map (PDF)

The deadline ledger

Post-Omnibus. Verified 27 July 2026 against Reg. (EU) 2026/1744 and Reg. (EU) 2024/1689 as amended. The free PDF contains the same table with full article citations.

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.	Unchanged
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

Guide No. 1 · first published 6 Jul 2026 · revised for Reg. 2026/1744

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 transparency timeline's last date: the window covers the machine-readable marking deadline. The Omnibus revision is the first of those updates, if you bought before 24 July, it is already in your library. Every purchase is an instant download with a VAT invoice via Gumroad, and carries a 14-day refund, no questions.

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

The free deadline map tells you when; the pack is the working kit for what and how. Bought Solo and later need the Agency licence? Email [email protected] and pay the difference.

Compliance notes

Working notes, dated. Opinions are ours. Older notes are left standing with corrections appended.

Is the EU AI Act delayed? Now a settled question. 27 Jul 2026: Reg. 2026/1744 is in force. Partial delay, unconditional dates, Article 50 untouched. Updated from the June version, which correctly predicted the outcome but cited the provisional text.
The Article 50 checklist 6 Jul 2026: five questions that scope your exposure. Holds up post-Omnibus; note added on the 50(7) codes-of-practice change.
The marking deadline, for the people who have to build it 6 Jul 2026, rev. 27 Jul: Art. 50(2) for engineering teams. Revised: new Art. 111(4) splits the deadline, day one for new systems, 2 Dec 2026 for legacy.

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 than a client alert and cost less 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.