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What is the Digital Omnibus? Definition and the new AI Act timeline
The Digital Omnibus is a package simplifying EU digital rules, presented by the European Commission on 19 November 2025. Its AI part, Regulation (EU) 2026/1744, in force since 27 July 2026, postpones the AI Act's high-risk obligations to 2 December 2027, while its data part, which would amend the GDPR, is still under negotiation as of 30 September 2026.
The term covers two separate texts that are often confused. The first, the “Digital Omnibus on AI”, became Regulation (EU) 2026/1744: adopted on 8 July 2026 and published in the Official Journal on 24 July, it has been in force since 27 July 2026. It amends the AI Act on three fronts. Timeline: obligations for Annex III high-risk systems (recruitment, credit, education) move from 2 August 2026 to 2 December 2027, and those for Annex I (AI embedded in already regulated products) from 2 August 2027 to 2 August 2028. Providers of generative systems already on the market before 2 August 2026 have until 2 December 2026 to apply machine-readable marking to their outputs (Article 50). Administrative burden: EU registration is kept but its content is simplified, and some relief reserved for SMEs is extended to small mid-caps. Substance: the AI literacy obligation (Article 4) becomes a duty to take measures, with no level prescribed, and two prohibitions are added to Article 5 (non-consensual intimate content, child sexual abuse material), applicable from 2 December 2026. The second text, the data “Digital Omnibus” (proposal COM(2025) 837), would amend the GDPR, cookie rules and the Data Act. As of 30 September 2026 it is still at first reading: the European Parliament's two co-rapporteurs published their draft report on 22 June 2026 and no trilogue has started. The GDPR therefore applies unchanged.
Concrete example
Illustrative case. A mid-sized company in Lyon with 900 employees publishes candidate pre-screening software, a use classified as high-risk under Annex III. It had budgeted its compliance work for August 2026. With the Omnibus, the deadline moves to 2 December 2027. The right use of these sixteen months: finish the technical documentation and risk management system calmly, rather than freezing the project. What does not change: the teams using and configuring the tool must already be AI literate (Article 4), and the chatbot on its website has had to disclose that it is an AI since 2 August 2026. On personal data, nothing changes: its legal basis and information to candidates remain governed by the current GDPR.
Comparison
| Obligation | Before the Omnibus | After the Omnibus |
|---|---|---|
| Prohibited practices (Article 5) | 2 February 2025 | Unchanged; two new prohibitions (non-consensual intimate content, child sexual abuse material) from 2 December 2026 |
| AI literacy (Article 4) | 2 February 2025, “sufficient level” to ensure | 2 February 2025, duty to take measures, no level prescribed |
| General-purpose AI models (GPAI) | 2 August 2025 | Unchanged |
| Transparency (Article 50) | 2 August 2026 | Unchanged; technical marking by 2 December 2026 for systems already on the market |
| High-risk, Annex III (recruitment, credit, education…) | 2 August 2026 | 2 December 2027 |
| High-risk, Annex I (already regulated products) | 2 August 2027 | 2 August 2028 |
| National regulatory sandboxes | 2 August 2026 | 2 August 2027 |
FAQ
What is the Digital Omnibus on AI?
It is Regulation (EU) 2026/1744, adopted on 8 July 2026 and in force since 27 July 2026. It amends the AI Act to simplify its implementation: postponed high-risk obligations, administrative relief, a reworded AI literacy obligation and two new prohibitions.
Does the Digital Omnibus change the GDPR?
Not so far. Changes to the GDPR and cookie rules are in a separate text, proposal COM(2025) 837 presented on 19 November 2025. As of 30 September 2026 it is still at first reading in the European Parliament and the Council, with no trilogue under way. The current GDPR applies in full.
Which AI Act deadlines did the Omnibus postpone?
Annex III high-risk systems move to 2 December 2027, Annex I systems (already regulated products) to 2 August 2028. Technical marking of generated content is required by 2 December 2026 for systems already on the market before 2 August 2026. Prohibitions, AI literacy, foundation model obligations and Article 50 transparency are not postponed.
What is the difference between the Digital Omnibus and the AI Act?
The AI Act (Regulation 2024/1689) is the substantive law governing AI in Europe. The Digital Omnibus is a package of amending texts: its AI part amends the AI Act without replacing it. To know your obligations, read the AI Act as amended by Regulation 2026/1744.
Where can I find the text of the AI Omnibus?
In the EU Official Journal of 24 July 2026, as Regulation (EU) 2026/1744, freely available on EUR-Lex in all official languages.
Do SMEs get any relief?
Yes. The AI Act already provided proportionate measures for SMEs (simplified documentation, adapted fine ceilings, priority access to regulatory sandboxes). The Omnibus extends part of this relief to small mid-caps.
See also
Further reading
AI Act, official European Commission page (timeline and texts)
Sources
- Regulation (EU) 2026/1744 of 8 July 2026 (Digital Omnibus on AI), amending Regulation (EU) 2024/1689, EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1744
- The Digital Omnibus Regulation Proposal, procedure 2025/0360(COD), Legislative Train Schedule, European Parliament, update of 1 August 2026. https://www.europarl.europa.eu/legislative-train/theme-a-new-plan-for-europe-s-sustainable-prosperity-and-competitiveness/file-digital-package
- AI Literacy, Questions & Answers, European Commission (Omnibus changes to Article 4). https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers