The EU AI Act:
promised in 100 days, delivered in phases

Executive summary

The Digital Omnibus on AI — Regulation (EU) 2026/1744, published in the Official Journal 24 July 2026 and in force since 27 July 2026 — defers high-risk obligations to 2 Dec 2027 (Annex III) and 2 Aug 2028 (Annex I embedded systems), now fixed in law rather than pending. Art. 50 transparency duties took effect on schedule, 2 Aug 2026; only a narrow watermarking grace period for legacy generative systems remains, expiring alongside the new AI-generated intimate-imagery ban on 2 Dec 2026. Prohibited practices have applied since Feb 2025, though the AI-literacy duty (Art. 4) was softened from an obligation to "ensure" literacy to one to "support the development of" it — a lower bar than the original text. The Omnibus also narrows the Annex I "safety component" definition, moves the Machinery Regulation from Annex I Section A to Section B, replaces the deleted Art. 10(5) with a new Art. 4a basis for bias-detection processing (subject to GDPR Art. 9 safeguards), creates a Small Mid-Cap Enterprise relief tier, and gives the AI Office exclusive enforcement over AI systems built on a GPAI model by the same provider or undertaking, plus systems integrated into DSA-designated VLOPs and search engines. The delay rewards firms that used it for inventory and classification, not those who paused.