On 19 November 2025 the Commission proposed the digital omnibus on AI (COM(2025) 836) — targeted amendments to the AI Act's implementation, including the timing of the high-risk requirements.
Status note. Superseded by the adopted text: the file was agreed provisionally on 7 May 2026 and formally adopted on 16/29 June 2026 (separate item). Kept in the record because the proposal defines the file's scope and start point.
What changed
The Commission adopted COM(2025) 836, a proposal for targeted simplification of certain AI Act provisions to ensure timely, smooth and proportionate implementation — including adjusting when the high-risk requirements apply. The Commission framed it as the first stage of its digital-simplification work, with a broader 'digital fitness check' to follow as a second stage. A proposal changes nothing by itself: the co-legislators' provisional agreement followed on 7 May 2026 and is recorded as a separate item in this feed.
Why it matters
This proposal opened the only formal route by which AI Act dates can move. Tracking the file from proposal to adopted text is the difference between re-planning on the Commission's opening position and re-planning on the law that actually emerges.
Who is affected
Anyone sequencing an AI Act compliance programme against the original timetable — the proposal marked the moment the high-risk dates stopped being safe planning anchors.
Rolescompliance teamslegal teamsAI governance leads
OrganisationsAI providersAI deployers
What to check next
- Compare the proposal's scope with the provisional agreement of 7 May 2026 to see what changed in negotiation
- Confirm any planning decisions reference the legislative file's current stage, not the proposal
- Check the Official Journal for the adopted amending regulation before treating any proposed date as final
Key dates
- 2025-11-19Proposal adopted by the Commission (COM(2025) 836)
Source. European Commission — digital omnibus on AI (proposal) ↗
Document: Proposal COM(2025) 836 — CELEX 52025PC0836
Verified by Trusq against this source on 17 Jul 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.
Document: Proposal COM(2025) 836 — CELEX 52025PC0836
Verified by Trusq against this source on 17 Jul 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.