The Digital Omnibus delay: what actually changed (the two-clock trap)
The Digital Omnibus (agreed May 2026) delayed high-risk AI Act obligations to December 2027 and August 2028 — but explicitly left Article 50 transparency rules on schedule for 2 August 2026. Reading 'AI Act delayed' as 'everything delayed' is the most common compliance mistake of 2026.
Why everyone is confused
The Digital Omnibus package was sold as simplification and delay — and it did delay the heavy machinery: Annex III high-risk obligations moved to 2 December 2027, Annex I to 2 August 2028. Headlines said "AI Act delayed".
What it did NOT touch
- Article 50 transparency duties — still 2 August 2026.
- GPAI obligations — already live since August 2025.
- The December 2026 marking grace period mechanics.
Why this is the trap
The transparency rules are the ones that apply to ordinary websites — your chatbot, your AI images, your AI text. The delayed rules mostly concern AI in recruitment, credit, critical infrastructure — things most marketing teams don't run. So the delay applies to rules you never had, while the rules you do have arrive on schedule. All the dates, clean →
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