What happened
- Regulation (EU) 2026/1744, known as the Digital Omnibus on AI, was published in the Official Journal of the European Union on July 24, 2026, and entered into force on July 27.
- It postpones the Annex III high-risk obligations until December 2, 2027, and the Annex I ones until August 2, 2028. The original date for both was August 2, 2026.
- The transparency obligations of Article 50 didn’t move and have applied since August 2, 2026: anyone operating a system that generates synthetic audio, images, video or text must make it identifiable as artificially generated.
- The machine-readable marking of Article 50(2) for systems already on the market applies from December 2, 2026, along with new prohibitions on non-consensual intimate images and child sexual abuse material.
Why it matters
- The postponement was read in headlines as the European Union suspending its AI law. It didn’t. The part that affects the most organizations (the one requiring disclosure that content was made by a machine) is precisely the part that was kept.
- It reaches operators outside the Union when the system’s output is used inside it. A Chilean studio producing synthetic assets for a brand with a European presence falls within the perimeter because of where the content goes, not where the studio is based.
- The Commission acknowledged that it postponed because the CEN-CENELEC harmonized standards and the conformity assessment bodies weren’t ready. The deadline moved for lack of compliance infrastructure, not because of a change of view on the risk.
The number
Six days. The distance between the entry into force of the regulation that moved the deadline and the deadline it was meant to move.
Context
The European AI law entered into force on August 1, 2024, with phased application. The Commission proposed the amendments on November 19, 2025. The political agreement came on May 7, 2026, Parliament endorsed it on June 16 and the Council approved it on June 29.
What’s next
- December 2, 2026: machine-readable marking for pre-existing systems and entry into force of the new prohibitions.
- August 2, 2027: member states must have at least one regulatory sandbox.
- December 2, 2027, and August 2, 2028: high-risk obligations, Annex III and Annex I.
Bottom line
In Chile, the Executive announced this week that it’s abandoning that same risk-based model before it has even been tried. Brussels took sixteen months to move its deadlines and got there with six days to spare.
This note summarizes regulatory deadlines and does not constitute legal advice.