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The Digital Omnibus has become binding law

Plans still based on the original high-risk dates or the former wording of Article 4 are no longer current.

Binding and in forceReassessment required

Source facts

What officially changed?

Regulation (EU) 2026/1744 was published on 24 July 2026 and entered into force on 27 July 2026. It directly amends the AI Act.

Legal effect

The core rules for Annex III systems apply from 2 December 2027 and those for the Annex I route from 2 August 2028. Article 4, the relationship between FRIAs and DPIAs, registration and the penalty regime were also amended.

What the status means

The change is binding and in force. Implementation and supervision may continue to develop.

Analysis by Responsible AI Platform

Why is this material?

Plans still based on the original high-risk dates or the former wording of Article 4 are no longer current.

What does this mean in practice?

Organisations have more preparation time for high-risk AI, but existing inventory, transparency and AI literacy measures remain necessary. Reliance on Article 6(3) does not remove the registration duty.

What may need to be reassessed?

  • Replace the former high-risk dates in policies, registers and project plans.
  • Check that Article 4 is described as a duty to take measures rather than an individual outcome duty.
  • Update FRIA and DPIA templates so relevant sections can cross-refer to each other.
  • Retain registration after an assessment under Article 6(3).

For whom and which provisions?

Perspectives

Using AI, Providing AI, Providing AI models, Advising, Educating, Public authority

Topics

AI literacy, High-risk AI, FRIA, Supervision and enforcement

Legal evidence

Official sources

Last checked by Responsible AI Platform: 8 August 2026.

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This analysis provides general information and is not legal advice for a specific situation.