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EU AI Act: Omnibus Law Pushes High-Risk Obligations to December 2027

August 2, 2026 was expected to be the EU AI Act’s largest compliance deadline. It was not. Here’s what’s happening to Europe’s most wanted regulation on artificial intelligence. 

EU AI Act: Omnibus Law Pushes High-Risk Obligations to December 2027

Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force on July 27, 2026, five days before the Act’s original application date, and postponed the high-risk obligations under Annex III from August 2, 2026 to December 2, 2027. High-risk obligations for AI embedded in regulated products under Annex I move to August 2, 2028. In simple words, the EU has given companies more time to comply with its toughest AI rules, delaying most requirements for high-risk AI systems from August 2026 to December 2027, and for AI built into regulated products until August 2028.

What Changes Today, What Does Not

The obligations that took effect on August 2, 2026 relate to enforcement powers over general-purpose AI (GPAI) rules already in force, not new high-risk requirements for most enterprises. The high-risk obligations everyone was bracing for slipped to December 2, 2027 and August 2, 2028, while the August 2, 2026 transparency deadline did not move. Two new prohibitions, covering AI-generated non-consensual intimate imagery and related material, take effect December 2, 2026.

The European Commission’s AI Office and national authorities begin enforcing the AI Act and the new transparency rules start to apply, covering chatbot disclosure, deepfake labelling, and machine-readable marking of AI-generated content. The release, however, does not reference Annex III, high-risk obligations, or conformity assessment, which are the categories the Omnibus postponed.

Why It Matters for Fintech

Several Annex III high-risk categories intersect directly with financial services, including credit scoring, insurance risk assessment, and benefit eligibility determination. The Digital Omnibus postpones the high-risk obligations for Annex III AI systems from August 2, 2026 to December 2, 2027, and the obligations for high-risk AI in regulated products under Annex I to August 2, 2028, but it leaves the Article 50 transparency rules and the Article 4 AI literacy duty exactly where they were. 

So, the new EU law delays strict compliance deadlines for high-risk AI used in areas like credit scoring and insurance, but the existing rules on AI transparency and staff AI literacy still apply on the original schedule.

This distinction matters for compliance planning. Credit scoring and KYC/AML AI tools classified as high-risk under Annex III gain until December 2027 before the full high-risk regime (i.e. risk management systems, technical documentation, data governance, human oversight, third-party conformity assessment) applies. Article 50 transparency obligations, covering AI chatbot and AI-content disclosure requirements, remain on the original timeline regardless of an AI system’s risk tier.

A transitional provision also affects systems already on the market: high-risk systems placed into service before the new application dates remain outside the full obligations until they undergo a significant design change. High-risk systems used by public authorities must comply by August 2, 2030, regardless of this exemption.

Nina Bobro

Nina Bobro

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https://payspacemagazine.com/author/nb/

Nina is passionate about financial technologies and environmental issues, reporting on the industry news and the most exciting projects that build their offerings around the intersection of fintech and sustainability.