AI Act after the Omnibus: delaying high-risk rules did not suspend the rest of the Regulation

The signal and the facts that change the decision

Regulation (EU) 2026/1744, in force since 27 July, changed the AI Act timetable. Sections 1 to 3 of Chapter III now apply on 2 December 2027 to high-risk systems under Article 6(2) and Annex III, and on 2 August 2028 to systems under Article 6(1) and Annex I. The general application date of 2 August 2026, however, did not disappear.

The consolidated text retains 2 August 2026 as the general date, with express exceptions; Articles 102 to 110 have applied since 27 July 2026. Certain new prohibitions in Article 5(1), points (ba) and (bb), and new paragraphs 1a and 1b apply on 2 December 2026, not in 2027.

Providers of systems generating synthetic content placed on the market before 2 August 2026 have until 2 December 2026 to take the necessary steps regarding Article 50(2). A superficial reading of the delay can freeze inventory, literacy, prohibitions, general-purpose model governance, transparency, or enforcement already in force; the opposite error is demanding today every high-risk section obligation that was expressly deferred.

Decision, limits, and stop condition

Replace any single line called ‘AI Act — 2027/2028’ with a calendar by article, role, system type, placing-on-market date, and obligation. Continue executing what already applies and use the additional high-risk time as an engineering and evidence window.

A superficial reading of the delay can freeze inventory, literacy, prohibitions, general-purpose model governance, transparency, or enforcement already in force; the opposite error is demanding today every high-risk section obligation that was expressly deferred.

Execution and proof of completion

Execution should start by inventorying systems, models, and roles and assigning each item an article, provisional classification, date, and legal-technical owner. Then, marking obligations active, transitional, or deferred, with a legal source and the condition that changes the status. Closure requires reviewing contracts, documentation, content marking, oversight, data, logs, and monitoring without waiting for the final high-risk date.

The dossier passes when every system has a timeline reproducible from the consolidated text, without dates inherited from old slides, and every active obligation has a control, owner, and operating evidence.

• inventorying systems, models, and roles and assigning each item an article, provisional classification, date, and legal-technical owner.
• marking obligations active, transitional, or deferred, with a legal source and the condition that changes the status.
• reviewing contracts, documentation, content marking, oversight, data, logs, and monitoring without waiting for the final high-risk date.
• The dossier passes when every system has a timeline reproducible from the consolidated text, without dates inherited from old slides, and every active obligation has a control, owner, and operating evidence.