Regulation (EU) 2026/1744 entered into force on 27 July 2026. The AI Act's high-risk deadlines are now 2 December 2027 for Annex III systems and 2 August 2028 for high-risk AI embedded in Annex I products.
Status note. The deferral is targeted. Article 50 still applies from 2 August 2026 except for the Article 50(2) machine-readable marking duty for systems already on the market before that date, which applies from 2 December 2026.
What changed
The digital omnibus on AI completed its legislative passage after the provisional agreement of 7 May, Parliament's adoption on 16 June and the Council's final green light on 29 June 2026. It was published on 24 July as Regulation (EU) 2026/1744 and entered into force on 27 July 2026. The binding dates are 2 December 2027 for stand-alone Annex III high-risk AI systems and 2 August 2028 for high-risk AI embedded in Annex I regulated products. The Article 50(2) machine-readable marking duty moves to 2 December 2026 only for systems placed on the market before 2 August 2026; the other Article 50 duties still apply from 2 August 2026.
Why it matters
The high-risk dates most programmes were built around have moved by 16–24 months and the change is now in force. Organisations can re-baseline those workstreams, but must not mistake the targeted deferral for a blanket delay of the AI Act.
Who is affected
Teams responsible for current or planned high-risk AI systems — both those relieved by the extra time and those with contractual commitments, certifications or product launches pinned to the original 2 August 2026 date.
Rolescompliance teamslegal teamsAI governance leadsproduct leads
OrganisationsAI providersAI deployers
What to check next
- Keep non-high-risk workstreams on the 2 August 2026 date — the deferral covers the high-risk requirements, not the whole Act
- Identify which of your systems fall in the Annex III track (December 2027) versus the embedded-product track (August 2028)
- Review whether any generative systems you placed on the market before 2 August 2026 rely on the content-marking postponement to 2 December 2026
- Re-baseline affected plans and contracts against Regulation (EU) 2026/1744
- Document which planning decisions were taken before and after the 27 July 2026 entry into force
Key dates
- 2026-05-07Provisional agreement between Parliament and Council
- 2026-06-16Adopted by the European Parliament (423/57/174)
- 2026-06-29Adopted by the Council — final green light
- 2027-12-02Annex III high-risk systems — binding application date
- 2028-08-02High-risk AI embedded in Annex I products — binding application date
Source. EUR-Lex — Regulation (EU) 2026/1744 ↗
Document: Regulation (EU) 2026/1744 — CELEX 32026R1744
Verified by Trusq against this source on 27 Jul 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.
Document: Regulation (EU) 2026/1744 — CELEX 32026R1744
Verified by Trusq against this source on 27 Jul 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.