Is the Digital Omnibus deadline shift already legally binding?

The European Parliament (16 June 2026) and the Council (29 June 2026) have both given final approval. The postponement only becomes legally binding once it is published in the Official Journal of the EU, expected before 2 August 2026. Until then, the original deadline formally still applies.

What exactly changes under the Digital Omnibus?

The main deadline for high-risk AI systems under Annex III moves from August 2026 to 2 December 2027. Product-integrated AI under Annex I (e.g. medical devices, machinery) moves from August 2027 to 2 August 2028. Art. 50 transparency obligations remain at 2 August 2026.

Do I still need to meet my GDPR obligations?

Yes, without exception. The Digital Omnibus only changes deadlines within the EU AI Act. GDPR is unaffected and continues to be enforced unchanged, regardless of whether or when your AI systems count as high-risk.

Does the EU AI Act even apply to me?

There is no blanket answer – it depends on whether you develop, distribute, or deploy AI systems and which risk category they fall into. Use the free quick check to find out where your company stands.

EU AI Act · Digital Omnibus

The AI Act deadline moved. That is not a reason to relax.

The European Parliament and the Council have given final approval to the "Digital Omnibus": the main deadline for high-risk AI under Annex III moves from August 2026 to 2 December 2027. What this actually means for your company – and why GDPR is entirely unaffected by the shift.

Status of this page: the European Parliament and the Council have both given final approval (16/29 June 2026). The new deadline only becomes legally binding once published in the Official Journal of the EU, expected before 2 August 2026.

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What actually changes

Short version – see the full timeline with every date on our deadlines page.

High-risk AI under Annex III

was: 2 August 2026

now: 2 December 2027

Product-integrated AI under Annex I

was: 2 August 2027

now: 2 August 2028

Transparency obligations (Art. 50)

unchanged

2 August 2026

View the full deadlines timeline →

What does not change: GDPR

The Digital Omnibus only changes deadlines inside the EU AI Act. Nothing changes about your GDPR obligations – records of processing, data subject rights, data protection impact assessments, breach notification. And according to Bitkom ("Datenschutz in der deutschen Wirtschaft", May 2026, 603 companies surveyed), 81% of companies feel burdened by existing data protection obligations. The AI Act deadline was never the only open item – it just stopped being the most urgent one.

The real blind spot: do you even know if you're affected?

According to Bitkom, a meaningful share of companies are still only just working out whether and to what extent the EU AI Act applies to them at all. That is the actual bottleneck – not the postponed deadline. If you don't know whether you're a provider or a deployer of a high-risk system, there's no deadline to relax about in the first place.

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Am I affected by the EU AI Act?

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What you’ll get

Instant risk classification
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Steps tailored to your role
Concrete recommendations for Compliance, IT, Legal or Management.
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Example result

High-risk AI

→ Create an AI inventory and document your high-risk systems.

Which systems count as high-risk (Annex III) →

⚖️ This check is not legal advice. If in doubt we recommend legal review.

What to do with the extra time

More time does not mean less work – it means you can do the work in a structured way instead of under time pressure. The order of operations stays the same, only the buffer got bigger.

Build your AI inventory now instead of waiting until shortly before the new deadline

Clarify provider vs. deployer role per system before investing in documentation

Keep GDPR obligations running as-is – there is no extension here

Use the extra runway for clean change management, not for procrastinating

Frequently asked questions about the Digital Omnibus

Is the deadline shift already legally binding?

The European Parliament (16 June 2026) and the Council (29 June 2026) have both given final approval. It only becomes legally binding once published in the Official Journal of the EU, expected before 2 August 2026. Until then, the original deadline formally still applies.

Why start now if there is more time?

Because a complete AI inventory and a defensible risk classification typically take several months – and because your GDPR obligations are enforceable right now, independent of this deadline.

Does the postponement apply to all AI systems?

No. It applies to the main application deadline for high-risk AI under Annex III (now: December 2027) and product-integrated AI under Annex I (now: August 2028). Prohibited practices, GPAI obligations, and Art. 50 transparency obligations (August 2026) are not affected.

Use the extra time in a structured way

SimpleAct helps you build AI inventory, risk classification, and documentation properly now – instead of scrambling right before the new deadline.

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