EU AI Act Post-Omnibus: All Deadlines at a Glance (As of October 2026)

As of October 22, 2026. In July 2026, the EU amended the AI Regulation (EU) 2024/1689 – the "EU AI Act" – via the Digital Omnibus Regulation on AI: Regulation (EU) 2026/1744 of July 8, 2026, published in the Official Journal of the EU on July 24, 2026, entering into force on the third day following publication. Several deadlines have shifted as a result. Here are all the dates that matter for businesses – complete with legal citations.

The Deadlines at a Glance

• Since February 2, 2025: General provisions and prohibited practices (Chapters I and II) – Art. 113(3)(a).
• Since August 2, 2026: Transparency obligations under Art. 50 (e.g., notifying users that they are interacting with AI) – general application date pursuant to Art. 113 of Regulation (EU) 2024/1689.
• December 2, 2026: New prohibitions for AI systems that generate intimate depictions of an identifiable person without explicit consent or generate child sexual abuse material – Art. 5(1), subpara. 1, points (ba) and (bb) in conjunction with Art. 113(3)(a).
• December 2, 2026: Providers of systems that generate synthetic audio, image, video, or text content and were already placed on the market before August 2, 2026, must comply with the labeling obligations under Art. 50(2) – transitional rule in Art. 111(4).
• December 2, 2027: Obligations for high-risk AI systems under Annex III (e.g., recruitment, credit scoring, education) – Art. 113(3)(c)(i). This was originally scheduled for August 2, 2026.
• August 2, 2028: Obligations for high-risk AI systems under Annex I, i.e., AI as a component of regulated products (e.g., machinery, medical devices) – Art. 113(3)(c)(ii).

What Has Changed Regarding AI Literacy

Art. 4 previously required companies to ensure a sufficient level of AI literacy among their staff. Under the revised version: Providers and deployers of AI systems "shall take measures to support the development of AI literacy of their staff and other persons". It explicitly states: This obligation "does not oblige providers or deployers to guarantee a specific level of AI literacy for any person" (Art. 4(1) as amended by Regulation (EU) 2026/1744; justification in Recital 8).

In practice, this means: Training and guidance for employees remain mandatory – but as supportive measures, not as a legal guarantee of a specific knowledge level.

What This Means for Your Company

• If you deploy AI in customer-facing roles (phone, chat, email), transparency obligations under Art. 50 have already been in effect since August 2, 2026.
• If you use AI to make decisions about individuals – such as in recruitment –, verify whether your use case falls under Annex III. You now have until December 2, 2027, to ensure compliance.
• Continue to upskill your team and document the measures you have taken to promote AI literacy.

Note on Earlier Articles

Our previous articles on the EU AI Act reflect the legal situation at their time of publication. Where deadlines have changed since then, this overview as of October 22, 2026, takes precedence.

This article provides a summary of the legislative text and does not constitute legal advice. The authoritative reference remains the official text in the Official Journal of the European Union.