AI Omnibus: Rebaseline Controls Without Stopping
The communicated timelines for high-risk systems change planning, but do not remove the need for documented preparation.
In brief
The Commission page on the AI Omnibus says the package entered into force on 27 July 2026 and communicates application dates for two high-risk system categories [claim-reg-omnibus]. The prudent decision is to rebaseline milestones, budget, and evidence without treating an extended timeline as an exemption from preparation [claim-reg-planeamento].
- Replan using the communicated dates for the stated categories.
- Keep preparation and control evidence in place.
- Review the plan when legislation or classification changes.
Communicated timeline
The Commission page states 2 December 2027 for Annex III high-risk systems and 2 August 2028 for high-risk AI embedded in physical products under Annex I [claim-reg-omnibus].
Management decision
It is an editorial recommendation to use the communicated dates to rebaseline the programme while retaining inventory, ownership, and validation work [claim-reg-planeamento].
Scope and review
This analysis is limited to the European Union and the Commission’s published description. Concrete classification and legal effect require case-specific assessment; review if the legislative text or use case changes [claim-reg-omnibus].
Sources consulted
Consulted on the stated update date.
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