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EU AI Act deadlines after the Digital Omnibus
*Engineering guidance, not legal advice. Check the Official Journal for the current status before relying on any date.*
In May 2026 the Council and the European Parliament reached a provisional agreement on the Digital Omnibus on AI (proposed by the Commission in November 2025). It postpones one chapter of the AI Act, not the whole Act.
What moved
| Obligation | Original date | New date |
|---|---|---|
| High-risk systems, standalone (Annex III: employment, credit, education, essential services, …) | 2 August 2026 | 2 December 2027 |
| High-risk systems embedded in regulated products (Annex I) | 2 August 2027 | 2 August 2028 |
This includes the high-risk requirements engineers care about: risk management, technical documentation, record-keeping (Art. 12), human oversight (Art. 14), and the deployer log retention duty (Art. 26).
What did not move
| Obligation | In effect since / from |
|---|---|
| Prohibited practices (Art. 5) | 2 February 2025 |
| AI literacy (Art. 4) | 2 February 2025 |
| General-purpose AI model obligations (Art. 51–56) | 2 August 2025 |
| Transparency duties (Art. 50: disclose AI interaction, label generated content) | 2 August 2026 |
Why engineering teams should not wait
- Logs cannot be backfilled. On the compliance date, the runs you did not record are gone. Record-keeping is the one obligation where starting late has a permanent cost.
- Buyers ask before regulators do. Enterprise procurement questionnaires already ask how AI decisions are logged and whether logs are tamper-evident.
- The dates have moved once. Planning around the next deadline is a bet on it staying put.
- Incidents do not wait for deadlines. An unexplained agent action next month needs an audit trail next month.
Where to start
Record every model call, tool call and policy decision at the call site, in a format whose integrity someone else can check (see tamper-evident logs). If you already emit OpenTelemetry GenAI traces, you have a head start.
Vetro Attest checks a Vetro ledger or OTLP trace for free and shows which record-keeping items are covered. For 29 USD it issues a counter-signed EU AI Act evidence report.
See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.