EU AI Omnibus 2026In forceEuropean Union

Digital Omnibus on AI (Regulation (EU) 2026/1744)

Last reviewed Sep 25, 2026.

In short

The Digital Omnibus on AI is the first amendment to the EU AI Act. Proposed in November 2025 and in force since 27 July 2026, it delays the high-risk obligations (Annex III to 2 December 2027, Annex I to 2 August 2028), gives generative systems already on the market until 2 December 2026 to add machine-readable marking, adds two prohibitions on AI that generates child sexual abuse material or non-consensual intimate imagery, replaces the AI-literacy article with a softer 'support' duty, and extends SME relief to small mid-caps.

Who it applies to

Organisations that build or use AI systems in European Union.
Any use case — it is not limited to specific applications.
Size: everyone, including solo operators.
Amends the AI Act rather than creating new duties for most companies. Matters most if you planned around the original August 2026 high-risk deadline or provide a generative AI system.

Key dates

Jul 24, 2026✓Published in the Official Journal
Jul 27, 2026✓Entered into force
Dec 2, 2026UpcomingNew prohibitions (AI generating CSAM / non-consensual intimate imagery) apply; marking grace period for existing generative systems ends
Aug 2, 2027UpcomingNational AI regulatory sandboxes must be operational (deferred from 2 Aug 2026)
Dec 2, 2027UpcomingAnnex III high-risk obligations apply (deferred from 2 Aug 2026)
Aug 2, 2028UpcomingAnnex I high-risk obligations apply (deferred from 2 Aug 2027)

What you have to do

Re-plan your high-risk roadmap around 2 December 2027 (Annex III) and 2 August 2028 (Annex I) — deferred, not cancelled.
If your generative system was on the market before 2 August 2026, add machine-readable output marking by 2 December 2026.
Make sure no product or feature can generate CSAM or non-consensual intimate imagery; that ban applies from 2 December 2026.
Keep the chatbot-disclosure and deepfake-labelling duties in place: those still applied from 2 August 2026.
Check whether you now qualify as an SME or small mid-cap for lighter documentation and lower fine caps.

Penalties

No separate penalty regime: the AI Act's Article 99 tiers continue to apply (up to EUR 35 million / 7%, EUR 15 million / 3%, EUR 7.5 million / 1%). The AI Office may also impose periodic penalty payments of up to 5% of average daily turnover on general-purpose AI providers.

Industries where it matters

Sources

Last reviewed Sep 25, 2026.