EU AI Act timeline after the omnibus: what applies when

The EU AI Act is Regulation (EU) 2024/1689. It was amended in 2026 by the Digital Omnibus on AI, Regulation (EU) 2026/1744, which was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026.

What applies when?

Sources: European Commission, AI Act page (application timeline); European Parliament, Legislative Observatory, summary of Regulation (EU) 2026/1744; European Commission, transparency obligations under Article 50; Regulation (EU) 2024/1689, EUR-Lex; Regulation (EU) 2026/1744, EUR-Lex.

What moved, and what did not?

Moved. The start dates of the main high-risk requirements, and a short extra period for marking AI-generated content made by systems already on the market. The omnibus also extends several simplified compliance measures for small and medium-sized enterprises to a new category of small mid-cap enterprises, and adds a prohibition, covering non-consensual intimate material and child sexual abuse material, that applies from 2 December 2026.

Did not move. The prohibitions already in force, the rules for general-purpose models, and Article 50, which still applies from 2 August 2026.

AI literacy was reworded, not removed. Providers and deployers must take measures to support AI literacy among their staff and the persons operating AI systems on their behalf. They are no longer required to guarantee a particular level of AI literacy for each individual. The Commission and the Member States must support these efforts, particularly for smaller companies.

Sources: European Parliament, Legislative Observatory, summary of Regulation (EU) 2026/1744; European Commission, AI Act page.

Does it apply to a US company?

Often, yes. The Act applies to providers placing AI systems or general-purpose AI models on the market in the EU, "irrespective of whether those providers are established or located within the Union or in a third country" (Article 2(1)(a)), and to providers and deployers established outside the EU "where the output produced by the AI system is used in the Union" (Article 2(1)(c)). A US company with EU customers should assume it is in scope until it has checked.

Source: AI Act Service Desk, Article 2.

What should a US company do in each period?

Now.

• Confirm that no product uses a prohibited practice, including the new one that applies from 2 December 2026.
• Keep a record of the measures taken on AI literacy (training, guidance, who received it).
• If you provide a general-purpose model, check the rules for providers of such models, including those on transparency and copyright.
• Check Article 50: AI systems that interact directly with people, such as chatbots, AI agents and avatars, must be designed so that people are informed they are interacting with AI; generative systems must mark their output (by 2 December 2026 for systems already on the market before 2 August 2026). See the Commission's questions and answers on Article 50.

Before 2 December 2027.

• Classify each AI system against Annex III. For each high-risk system, plan the risk management system, data governance, technical documentation, logging, human oversight and the conformity assessment.
• Some deployers of high-risk systems, including bodies governed by public law and private entities providing public services, must carry out a fundamental rights impact assessment (Article 27).

Before 2 August 2028.

• If your AI is a product, or a safety component of a product, covered by the EU product laws in Annex I, align the AI Act requirements with that product's conformity assessment.

Source: AI Act Service Desk, Article 27.

Checklist

• Inventory of AI systems and models, with the role you hold for each (provider, deployer, importer, distributor)
• Prohibited practices excluded, including the new prohibition
• AI literacy measures recorded
• Article 50 disclosures in place; marking of generated content scheduled
• Annex III classification done; plan for 2 December 2027
• Annex I products identified; plan for 2 August 2028

Questions people ask

Was the AI Act delayed? In part. The main high-risk requirements start later (2 December 2027 and 2 August 2028). The other dates did not move.

Do the transparency rules apply now? Yes, Article 50 applies from 2 August 2026. Generative systems already on the market before that date have until 2 December 2026 to mark their output.

Is AI literacy still required? Yes. Providers and deployers must take measures to support it, but need not guarantee a particular level for each person.

Do we need to do anything about high-risk systems before December 2027? The requirements do not apply before then, but the work (classification, documentation, testing) takes months, and contracts with EU customers often ask for it earlier.

Update log

• 16 October 2026: first published, with the dates of Regulation (EU) 2026/1744. This guide is reviewed monthly. Sources checked the same day; the new prohibition is described as one prohibition, as the Commission counts it.