Direct answer
What did the Digital Omnibus shift and what still applies as planned?
You describe: You want the current timeline: which obligations were postponed and which deadlines stand. Likely role: every role.
This applies now
- Article 50: transparencyApplicable
- Article 4: AI literacyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
- Article 27: FRIAfrom 2 December 2027
Regulation (EU) 2026/1744 is in force since 27 July 2026: high-risk Annex III moves to 2 December 2027 and Annex I to 2 August 2028. Not shifted: the prohibited practices, Article 4, Article 50 and GPAI enforcement. Next date: 2 December 2026.
Your first actions
- Classify the use case and document the outcome. Assess Article 5, Article 6 and Annex III in that order and document purpose, context and any Article 6(3) exception.
- Perform a FRIA before deployment. Assess process, duration, affected persons, risks, oversight, mitigation and complaint mechanisms and notify results where required.
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
Record this
- Article 6 and Annex III classification record
- FRIA report and notification
- Transparency implementation record
General interpretation, not legal advice. The official source remains authoritative.
Full map for your situationExecution
Record the classification in an AI register
A classification without a register and ownership is not demonstrable. Embed AI guides classification, register and reassessment in a fixed approach.
See the Embed AI approach