Quick answer
The EU AI Act Digital Omnibus is now a provisional-agreement planning issue, not merely a proposal watch item. It would delay certain high-risk AI obligations to 2 December 2027 and product-integrated high-risk AI rules to 2 August 2028 if formally adopted and published. Until then, Regulation (EU) 2024/1689 remains the current published legal baseline.
Need to know which track applies?
Use the Omnibus Deadline Router to separate current-law baseline work from provisional 2027 and 2028 planning tracks for one AI system.
Run the Omnibus Deadline Router →Digital Omnibus update, 9 May 2026
EU co-legislators reached a provisional agreement on 7 May 2026 that would change parts of the EU AI Act implementation timeline. Certain high-risk AI obligations would move to 2 December 2027, and product-integrated high-risk AI rules would move to 2 August 2028 if the amendment is formally adopted and published. EU AI Compass keeps current-law and provisional-agreement planning tracks separate.
What changed on 7 May 2026
The Commission announced that EU co-legislators had reached a provisional agreement on AI Act simplification measures. For EUAICompass.com, the important point is not only the later dates. The important point is the status line: provisional agreement first, formal adoption later, legal text change only after publication and entry into force.
That distinction has to be visible on the website because many deployer teams will read the news as permission to stop. That would be a weak control decision.
| Planning item | Current published AI Act baseline | Provisional-agreement track | EU AI Compass action |
|---|---|---|---|
| Certain Annex III high-risk AI systems | Most high-risk obligations remain scheduled for 2 August 2026 under the current published baseline. | Would move to 2 December 2027 if formally adopted and published. | Show both tracks and keep evidence work active. |
| High-risk AI integrated into products | Some systems linked to product safety remain scheduled for 2 August 2027 under the current published baseline. | Would move to 2 August 2028 if formally adopted and published. | Flag product-safety overlap and avoid treating the later date as final law. |
| Article 50 transparency | Article 50 remains part of the current-law 2 August 2026 planning baseline unless final adopted text changes it. | The provisional-agreement package indicates a 2 December 2026 planning date for certain transparency-solution timing for artificially generated content, but final scope must be checked carefully. | Review Article 50 pages separately and do not assume all transparency duties moved to 2027. |
| SME and deployer evidence work | Inventory, vendor evidence, oversight, logs, and disclosure records remain useful. | Later dates may change sequencing, not the need for evidence. | Route users to the deadline tracker and evidence checklist. |
What deployers should keep doing
- Inventory AI systems: capture owner, vendor, purpose, user group, data categories, and lifecycle status.
- Separate role and risk assumptions: record why the organisation is acting as a deployer, provider, importer, distributor, or product manufacturer.
- Ask vendors for evidence: retain instructions for use, technical documentation extracts, oversight information, data governance summaries, and update notices.
- Review Article 50 triggers: chatbot, synthetic content, deepfake, emotion-recognition, and biometric-categorisation notices still need operational routing.
- Maintain a status log: record whether a decision relied on current law, provisional agreement, draft guidance, or final adopted text.
What should not be treated as final yet
Do not write internal policy as if the Digital Omnibus has already amended Regulation (EU) 2024/1689. Do not tell product, procurement, or AI governance owners that the August 2026 track has disappeared. The safer memo says: current published law remains the baseline, the provisional agreement may change the timeline, and the evidence programme should now be sequenced against both tracks.
Open the master timeline
See current-law and provisional-agreement dates in one place.
Compare legal-status tracks
Use the current-law, provisional-agreement, and final-adoption view.
Digital Omnibus cluster
Use the cluster in the right order.
Start with the router, then open the guide that matches the planning track: standards readiness, product-integrated AI, or SME and small-mid-cap relief.
Omnibus Deadline Router
Separate current-law dates from 2026, 2027, and 2028 planning tracks for one AI system.
GUIDE · 5 MINStandards Readiness After the Omnibus
Build evidence structures that can absorb harmonised standards and common specifications when they arrive.
GUIDE · 5 MINProduct-Integrated AI Systems and 2028
Connect AI Act planning with the product safety file, supplier evidence, and sectoral-law overlap.
GUIDE · 5 MINSmall Mid-Cap Relief After the Omnibus
Treat SME and small-mid-cap relief as a planning issue, not an exemption from records.
Frequently asked questions
Is the EU AI Act Digital Omnibus provisional agreement already law?
No. The EU AI Act Digital Omnibus provisional agreement is not treated as final law on EU AI Compass until formal adoption and publication occur. Until then, Regulation (EU) 2024/1689 remains the current published baseline for legal-text planning.
What would change for high-risk AI systems?
The provisional agreement would move certain high-risk AI obligations to 2 December 2027 if formally adopted and published. The affected planning track includes high-risk systems such as biometric, education, employment, critical infrastructure, migration, asylum, border control, law enforcement, and related Annex III use cases.
What would change for product-integrated high-risk AI systems?
The provisional agreement would move high-risk AI systems integrated into products, such as lifts or toys, to 2 August 2028 if formally adopted and published. Product teams should still map the AI system, sectoral safety rules, conformity route, vendor evidence, and owner before treating the later date as usable planning time.
Should deployers stop preparing for August 2026?
No. Deployers should not pause evidence work. A safer approach is to split the file into current-law obligations, provisional-agreement watch items, and evidence that will be useful under either track: inventory, vendor records, oversight notes, user instructions, logs, and Article 50 checks.
What should EU AI Compass users do next?
Use the Digital Omnibus update as a planning control, not a reason to wait. Start with the timeline page, check whether the AI system could be high-risk, and keep a dated evidence file showing the regulatory status used for each internal decision.
Last evidence review date: 9 May 2026
Source basis: Regulation (EU) 2024/1689 remains the current published EU AI Act baseline. This page also tracks the official 7 May 2026 Digital Omnibus provisional agreement reported by the European Commission and related EU institutional reporting. The agreement still requires formal adoption and publication before it changes the legal text. This page is for operational planning and is not legal advice.
Regulation (EU) 2024/1689 · European Commission press release IP/26/1024 · Council provisional-agreement press release
Keep the evidence work moving
The Digital Omnibus may change timing, but it does not remove the need to know which AI systems exist, who owns them, which vendor records support them, and what evidence a deployer can show.