The Week in One Line

The high-risk AI deadline you have heard about for a year just moved. Here is exactly what changed and what did not.

What the Act Actually Says

On 7 May 2026, the Council of the EU and the European Parliament reached a provisional political agreement on the Digital Omnibus on AI, the first amendment package to the EU AI Act since it was adopted in 2024.

The change: high-risk obligations for stand-alone Annex III systems (recruitment, credit scoring, education, employment, law enforcement, border control) are deferred from 2 August 2026 to 2 December 2027, a 16-month extension. High-risk obligations for AI embedded in regulated products under Annex I (medical devices, machinery) move from 2 August 2027 to 2 August 2028.

This is not yet final law. It takes effect only once formally adopted and published in the Official Journal, expected before 2 August 2026. Until then, the original 2 August 2026 deadline remains technically active.

What did not change: Articles 53-55 covering GPAI model provider obligations have applied since August 2025 and are untouched by this agreement. The Article 50 transparency and watermarking obligation actually moved in the opposite direction. Its grace period was shortened, with a new deadline of 2 December 2026.

Source: Council of the EU press release, 7 May 2026, "Artificial Intelligence: Council and Parliament agree to simplify and streamline rules"

What This Means for Your Business

If your AI system falls under Annex III (hiring, credit scoring, education, etc.), you now have until 2 December 2027 rather than 2 August 2026, but only once this is formally adopted, which is expected to happen before August.

Do not stop your compliance work. The inventory and classification work this newsletter has pointed you toward does not get easier by waiting. Starting now gives you 18 months to refine. Waiting until late 2027 gives you weeks.

If your product generates AI content (text, image, audio, video), the watermarking deadline of 2 December 2026 was not delayed. It is now closer than the high-risk deadline for many companies.

A new prohibition was added to Article 5: AI systems that generate non-consensual intimate imagery or CSAM, with a compliance date of 2 December 2026.

This Week's Action Point

Update your internal compliance tracker with the corrected dates:

• 2 December 2027 for Annex III systems

• 2 August 2028 for Annex I systems

• 2 December 2026 for the watermarking obligation under Article 50

Flag clearly that the high-risk dates are not yet legally binding until formal publication, but treat them as the planning baseline, as the AI Office and major law firms are already doing.

Further Reading

Council of the EU press release on the Omnibus agreement: consilium.europa.eu (search "Artificial Intelligence Council Parliament simplify streamline rules")

artificialintelligenceact.eu – Implementation Timeline (updated)

Next Tuesday: GPAI Models: what providers must do now, who actually qualifies as a provider, and where many organisations misunderstand their obligations.