The next deadline scheduled under the AI Act is 2 August 2026. This was set to become an important milestone on which most obligations would become applicable. A few days ago, however, the EU partially adjusted the timeline. For many organisations, several important provisions will still become applicable on 2 August, but a number of deadlines have been postponed for a little longer.
Just in time: the Digital Omnibus
On 24 July 2026, the "Digital Omnibus on AI" (Regulation (EU) 2026/1744) was published in the Official Journal of the EU. This Regulation entered into force on 27 July 2026 and amends the AI Act on a number of points. The media’s attention is mainly focused on the postponement of certain obligations. Do not be misled, however: the postponement applies only to the most burdensome obligations. For companies that use AI in customer contact or content creation, this date therefore remains highly relevant.
Which obligations apply from 2 August 2026?
The transparency obligations under Article 50 have not been postponed and will still apply from 2 August 2026.
In concrete terms, this means:
- providers of an AI system that interacts directly with a person, such as a chatbot or virtual assistant, must make clear that the user is dealing with AI, unless this is obvious from the context of use;
- providers of generative AI systems must provide a machine-readable marking for AI-generated audio, images, videos and text. For systems already placed on the market before 2 August 2026, an additional transitional period until 2 December 2026 applies in this respect;
- deployers that generate or manipulate deepfake images, audio or video with AI must clearly label these materials as such;
- deployers that use systems for emotion recognition or biometric categorisation must inform the persons subjected to them accordingly;
- deployers that use AI to generate or manipulate texts must label that text as such only where the text is published with the purpose of informing the public on matters of public interest, insofar as that text has not been subject to human review and no natural or legal person bears responsibility for it.
Does your company have a chatbot on its website, use AI for marketing content, or publish AI-generated images or videos? If so, you will very likely soon have to observe these transparency obligations.
The AI Act does not specify in concrete terms how providers and deployers must comply with these obligations. However, the EU has published a Code of Practice and several optional pictograms.
It is also important to mention that all provisions concerning enforcement at European and national level will likewise become applicable on 2 August. Compliance with all rules that are already active will therefore soon also be enforceable. One caveat, however, is that the establishment of a Belgian enforcement authority is still ongoing.
Which deadlines have been postponed?
The obligations for AI systems classified as high-risk (see Annex III to the AI Act), such as systems used for recruitment, credit scoring, evaluation in education or access to essential services, are postponed from 2 August 2026 to 2 December 2027.
For AI systems embedded in products that already fall under other European product legislation (see Annex I to the AI Act), such as medical devices, machinery or toys, the deadline shifts to 2 August 2028.
Importantly, only the timing changes. The content of these obligations remains unchanged. Those who have already started preparing would therefore do well to continue that process.
What else is new?
The Digital Omnibus also adds a new prohibited AI practice. From 2 December 2026, the use of AI to generate non-consensual intimate images ("nudifiers") and child sexual abuse material is expressly prohibited.
What does this mean for you?
For compliance with the high-risk obligations, companies have been given somewhat more time, until December 2027 or August 2028. However, the transparency obligations under Article 50 apply in full from 2 August 2026. Anyone using AI in, among other things, direct customer contact or content creation cannot avoid them.
Stay tuned for our practical checklists on how your company can comply with its obligations. You can also contact us at any time with questions about your specific obligations under the AI Act.