EU AI Act timeline after the Digital Omnibus: what applies when
The Digital Omnibus, Regulation (EU) 2026/1744, entered into force on 27 July 2026 and rewrote the application dates of the EU AI Act, Regulation (EU) 2024/1689. The high-risk chapter moved. The transparency duties did not. Several versions of the EU AI Act timeline have circulated since, some still repeating the original 2026 date for Annex III systems. This article sets out the AI Act dates as they stand in the consolidated text, what each one means for a bank or an insurer running AI agents, and what should be on file by each of them.
What applies today
Most of the regulation already applies. Chapters I and II have applied since 2 February 2025: the definitions, the Article 5 prohibitions and the Article 4 duty on AI literacy. The obligations on general-purpose AI models, the governance chapter and the penalties chapter have applied since 2 August 2025. On 2 August 2026 the regulation became applicable as a whole, subject to the exceptions in Article 113. The Article 50 transparency duties, the market surveillance chapter and the Article 101 fines on general-purpose AI providers all date from that day. The timeline below shows where each provision stands.
- In force
Chapters I–II: definitions, the Article 5 prohibited-practice list, and the Article 4 AI-literacy duty.
- In force
GPAI model obligations (Chapter V), governance (Chapter VII), notified bodies (Chapter III Section 4), and penalties. Legacy GPAI models placed before this date: 2 Aug 2027.
- In force
Article 50 transparency duties; Chapter IX market surveillance; Article 101 (Commission fines on GPAI providers).
- Pending
Article 50(2) machine-readable marking grace ends for systems placed on the market before 2 Aug 2026; the two new Article 5 prohibitions, 5(1)(ba) and 5(1)(bb), apply.
- Pending
Regulatory sandboxes (Article 57); the legacy-GPAI deadline (models placed before 2 Aug 2025 must be compliant).
- Pending
Chapter III Sections 1, 2 and 3 for Annex III stand-alone high-risk systems: classification, the high-risk requirements (Arts 8–15), and the provider/deployer obligations (Arts 16–27).
- Pending
Chapter III for Annex I embedded (product-safety-component) high-risk systems.
- Pending
Pre-existing high-risk AI systems operated by public authorities (placed on the market before 2 Aug 2027).
- Pending
AI systems that are components of the large-scale IT systems listed in Annex X (Freedom, Security and Justice).
Article 4 asks providers and deployers to take measures that support the AI literacy of the staff who operate AI systems, without guaranteeing any level for a given individual. Article 5 prohibits, among other practices, manipulative techniques that distort behaviour and cause significant harm, and the exploitation of vulnerabilities linked to age, disability or economic situation. A collections assistant that steers a customer in difficulty is the scenario a compliance officer should test.
Article 50 is the provision most banks are living with right now. Since 2 August 2026, an AI system that talks to a natural person must say what it is:
Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use. (Article 50(1))
Article 50(5) fixes the moment: clearly, in a way that stands out, and no later than the first interaction. Two reference documents arrived just before the date: the Code of Practice on Transparency of AI-Generated Content, finalised on 10 June 2026, and the Commission Guidelines on Article 50, published on 20 July 2026. A product owner should read both against the assistant's opening screen.
Two provisions are in dispute after the Omnibus because the sources conflict on their date: Chapter III Section 5, Articles 40 to 49, and Article 86 on the right to an explanation. Treat both as possibly applying now, confirm with counsel.
What changes on 2 December 2026
Two things happen on this date. The first concerns generative systems already on the market:
Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, that have been placed on the market before 2 August 2026 shall take the necessary steps in order to comply with Article 50(2) by 2 December 2026. (Article 111(4))
Article 50(2) requires the outputs of a generative system to carry a machine-readable mark and to be detectable as artificial. For systems placed on the market from 2 August 2026 the duty already applies. A generative assistant that drafts emails or documents for customers, and was in production before 2 August 2026, must carry the marking by 2 December 2026. The same paragraph exempts assistive editing that does not substantially alter the deployer's input. Whether a feature qualifies is a decision for the product owner with counsel, written down before the date.
The second change is to Article 5. Points (ba) and (bb) of Article 5(1) apply from 2 December 2026. Point (ba) prohibits systems that generate or manipulate realistic intimate imagery of an identifiable person without explicit consent. Point (bb) prohibits systems that generate child sexual abuse material. Under Article 5(1a), placing such a system on the market is prohibited where that generation is its intended purpose, or where its design makes it a foreseeable and repeatable result and the system lacks adequate technical safeguards. Use is prohibited where the deployer uses it for that purpose. Any generative capability open to the public should have that safeguards test documented.
Annex III high-risk obligations from 2 December 2027
The consolidated Article 113 now reads:
Chapter III, Sections 1, 2, and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and (ii) 2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I (Article 113, point (c))
Sections 1 to 3 of Chapter III are the core of the high-risk regime. Section 1 holds the classification rules of Article 6. Section 2 holds the requirements of Articles 8 to 15, from risk management and data governance to human oversight and cybersecurity. Section 3 holds the obligations of providers and deployers in Articles 16 to 27.
For a bank, the relevant entry is Annex III, point 5, which covers the financial use cases, among them creditworthiness assessment and credit scoring of natural persons. Article 72(4) lets an institution subject to Union financial services law fold the post-market monitoring plan into the systems it already runs, provided the protection is equivalent. Article 73(9) limits serious incident notification to the incidents defined in Article 3, point (49)(c), where the provider is bound by equivalent Union reporting obligations. The Article 73 clocks are short: 15 days as a rule, two days for a widespread infringement, 10 days where a person has died.
One rule on existing systems matters for planning:
this Regulation shall apply to operators of high-risk AI systems... that have been placed on the market or put into service before the date of application of Chapter III referred to in Article 113, only if, as from that date, those systems are subject to significant changes in their designs. (Article 111(2))
A scoring system in production before 2 December 2027 stays outside Chapter III until its design changes significantly. A retrained model, a new feature set or a change of vendor may or may not be such a change. Decide with counsel and record the reasoning, because a supervisor will ask.
Annex I from 2 August 2028
The second high-risk date concerns AI systems that are safety components of products covered by the Union harmonisation legislation in Annex I, or that are themselves such products, where the product needs a third-party conformity assessment (Article 6(1)). The Omnibus also narrowed the notion of a safety component. Article 6(1a) excludes systems used only for user assistance, performance optimisation, service efficiency, automation, convenience or quality control. Article 6(1b) brings back any system whose failure would endanger health and safety.
A bank rarely provides an Annex I system. An insurer that embeds AI in a connected device, or a group with an industrial subsidiary, may. Two later dates close the timeline. High-risk systems intended for public authorities must comply by 2 August 2030, and AI components of the Annex X large-scale IT systems by 31 December 2030 (Article 111). Neither binds a private bank.
What the deferral does not change
The Omnibus moved dates. It did not move the boundary between classes. Article 6 answers the classification question today, on the criteria that will bind from 2 December 2027. Article 6(3) lets an Annex III system out of the high-risk class where it poses no significant risk of harm, for example a narrow procedural task or a preparatory task. The derogation has one hard limit:
Notwithstanding the first subparagraph, an AI system referred to in Annex III shall always be considered to be high-risk where the AI system performs profiling of natural persons. (Article 6(3))
An assistant that draws on a customer's profile to decide what to offer, or that pre-screens a loan application, should be classified now, with the Article 6(4) assessment written down, even though the duty to hold it only bites in December 2027. The registration that Article 6(4) points to, Article 49(2), sits in Chapter III Section 5, possibly applying now, confirm with counsel.
Article 50 was never part of the deferral. It has applied since 2 August 2026, and the December date only extends the marking duty to older systems. Article 50(6) states that paragraphs 1 to 4 do not affect the requirements of Chapter III. A high-risk assistant will carry both sets of duties.
DORA, Regulation (EU) 2022/2554, has applied to financial entities since 17 January 2025, and the Omnibus did not touch it. An AI agent that answers customers, calls internal tools or reads account data is an ICT system in DORA terms. ICT risk management, incident reporting, resilience testing and ICT third-party risk apply to it now, whatever class the EU AI Act gives it. Where a vendor supplies the agent, the register of information is due today, not in 2027.
A calendar for a bank's AI governance team
The EU AI Act timeline below, written for a bank, uses only the dates in the consolidated text. Each line is a decision that leaves a document behind.
- Since 17 January 2025. Treat every AI agent as an ICT asset under DORA: risk register, register of information, incident classification, resilience testing and the third-party rules for its vendor.
- Since 2 February 2025. Screen every AI system against the Article 5 prohibitions and keep the record. Document the Article 4 literacy measures for the staff who operate the agents.
- Since 2 August 2025. Collect the documentation your general-purpose AI model providers owe you.
- Since 2 August 2026. Confirm that every customer-facing assistant discloses its nature at the first interaction, as Article 50(1) and 50(5) require, checked against the Guidelines of 20 July 2026.
- By 2 December 2026. Apply the Article 50(2) marking to every generative system that was in production before 2 August 2026. Document the Article 5(1a) safeguards test for any image, video or audio generation open to the public.
- By 2 August 2027. Decide whether the Article 57 regulatory sandbox serves a planned high-risk system. Close the review of general-purpose AI models placed on the market before 2 August 2025 with your vendors.
- By 2 December 2027. Hold a signed classification for every Annex III candidate, with the Article 6(3) reasoning and the Article 6(4) assessment where the conclusion is not high-risk. Where the bank is provider, meet Articles 8 to 15 and 16 to 27, integrate the monitoring plan under Article 72(4) and rehearse the Article 73 clocks. Where it is deployer, meet the deployer obligations.
- By 2 August 2028. Confirm whether any AI component sits in an Annex I product. For most banks the answer is no, and that answer belongs on file.
- 2 August 2030 and 31 December 2030. Recognise these in vendor material as the public authority and Annex X deadlines. They do not bind a private bank.
Every line starts with the same question: which class the agent falls in, and therefore which date binds it. Vidimus turns each applicable article into tests, runs them against the live agent, records the tool calls it makes, grades every answer with a separate grading model, has a human reviewer confirm and issues a versioned, signed evidence pack. A pilot takes about two weeks for one agent. To place your agent on the timeline, start with the free EU AI Act risk classifier.