EU AI Act Omnibus Is Law: Transparency Rules Hit August 2

The EU's Digital Omnibus package amending the AI Act was published in the Official Journal on July 24 and entered into force on July 27. The practical summary for anyone selling into Europe: the heaviest compliance dates just moved years into the future, while the transparency rules arrive this Sunday, August 2, exactly as scheduled.

Deferred: the high-risk regime

Obligations for standalone high-risk systems listed in Annex III, covering areas such as hiring, credit scoring, and biometrics, shift from August 2, 2026 to December 2, 2027. Product-embedded systems under Annex I move from August 2027 to August 2028. This is the part of the law that requires conformity assessments, risk management systems, and extensive documentation, so the deferral is a genuine reprieve for vendors that were racing an impossible clock.

Not deferred: Article 50 and enforcement powers

Three things take effect on August 2: Article 50 transparency obligations, the Commission's power to fine general-purpose AI providers, and full investigation and sanction powers for national market surveillance authorities. In concrete terms, users must be told when they are talking to a chatbot, deepfakes must be labeled, and AI-generated content needs machine-readable marking.

To make that concrete: a support chatbot serving customers in Berlin can no longer present itself as human after Sunday, and an AI-generated product image cannot ship unmarked. The obligation also does not stop with model makers; whoever puts the system in front of users shares responsibility. In practice, machine-readable marking is being met with watermarking and content-credential standards, and teams that assembled their own tooling will need to add that layer themselves.

Reading the deferral as Brussels backing down would be a mistake. The EU postponed the part that is most expensive to implement while keeping the part that is most visible to ordinary users precisely on schedule. Disclosure comes first; heavy compliance follows.

How to treat the deadline if you sell into the EU

The AI Act follows the user, not the company headquarters: a SaaS product operated from anywhere counts once it serves EU users. Our suggested order of work this week: inventory first, mapping which products expose which AI features to EU users; add a plain chatbot disclosure now; and build content marking into your pipeline rather than bolting it on later. As for the high-risk deferral, treat it as time to prepare rather than permission to forget. December 2027 sounds distant, but in enterprise sales terms it is barely two budget cycles away, and the direction of the regulation has not changed at all.

Sources: Freshfields, European Commission