Executive Summary
The market is mixing up two different things: binding dates already in the AI Act and later dates proposed in the Digital Omnibus on AI. Those are not the same. If you merge them into one timeline, you create planning noise and legal risk.
Reviewed through 20 April 2026, the safe operating model is simple: keep the legal baseline as primary, and show the Omnibus only as a secondary proposed track until it is adopted.
The dates that are confirmed
These dates are part of the current legal baseline and should sit in your planning model unless and until the law changes:
| Date | Status | What applies |
|---|---|---|
| 2 February 2025 | Confirmed law | Article 5 prohibited practices and Article 4 AI literacy. |
| 2 August 2025 | Confirmed law | General-purpose AI model rules. |
| 2 August 2026 | Confirmed law | Article 50 transparency rules and Annex III high-risk obligations. |
| 2 August 2027 | Confirmed law | Annex I product-safety AI systems. |
| 2 August 2030 | Confirmed law | Certain public-authority legacy high-risk system treatment under transitional rules. |
What the Omnibus proposal would change
The Digital Omnibus on AI is a live legislative proposal. Its core purpose is to simplify implementation where standards and tooling are not ready. That matters most for the Annex III and Annex I dates. But it remains a proposal in the ordinary legislative procedure, not adopted law.
As of 20 April 2026, the Council adopted its position on 13 March 2026, Parliament adopted its negotiating position on 26 March 2026, and trilogue negotiations have launched. A second political trilogue is planned for 28 April 2026. None of that changes the current-law baseline yet.
Operationally, the proposal creates a second scenario, not a replacement baseline:
| Area | Current law | Proposal track |
|---|---|---|
| Annex III high-risk systems | 2 August 2026 | 2 December 2027 if the Omnibus is enacted in the form now under negotiation. |
| Annex I product-safety AI systems | 2 August 2027 | 2 August 2028 if the Omnibus is enacted in the form now under negotiation. |
| Article 50 transparency | 2 August 2026 | Parliament has floated proposal-stage watermarking transition dates of 2 November 2026 and 2 February 2027, but those are not current law. |
| Article 5 and Article 4 | Already applicable | No delay. These are live now. |
What SMEs should do with this
- Build against current law first. Your documentation, training, controls, and audit planning should still reference the live AI Act dates.
- Add a secondary scenario. Track how your internal milestones would shift if the Omnibus is adopted.
- Do not stop implementation. Article 4, Article 5, GPAI work, and Article 50 readiness still matter regardless of any Annex III debate.
- Expose the distinction to users. If your product shows timelines, it should mark each item as confirmed law, proposal, or monitor only.
Product recommendation for EU AI Compass
Your app should use a dual-timeline architecture: current law and proposed Omnibus. Do not overwrite the legal baseline. Make the proposal visible, but visibly subordinate to the confirmed track.
Use the Regulatory Timeline as the customer-facing source of truth, and the Compliance Checker to link each date to operational obligations.
About the author: Abhishek G Sharma is the founder of Move78 International Limited. He holds ISO 42001 Lead Auditor, CISA, CISM, CRISC, and CEH certifications.
Disclaimer: This page is educational and operational guidance only. It is not legal advice. Published: March 2026. Reviewed through April 20, 2026.