IddiLabs · EU AI Act tool · v1.0 · July 2026

AI Act Compliance Clock

The Digital Omnibus on AI moved the AI Act's high-risk dates — but it didn't move all of them. This page shows the revised timeline, what changed versus what still lands on 2 August 2026, and a quick check of whether the Article 50 transparency duties apply to you.

Omnibus adopted by Council 29 Jun 2026 · OJ publication pending · amendments bind 3 days after publication
Unchanged deadline

Article 50 transparency & GPAI enforcement — 2 August 2026

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The Omnibus deferred the high-risk obligations. It left most of Article 50 — chatbot disclosure, synthetic-content marking, emotion-recognition and deepfake notices — on the original date, and Commission fining powers over GPAI providers begin the same day.

01 · Revised timeline

What applies when — post-Omnibus

Struck-through dates are the original AI Act dates replaced by the Omnibus. Everything else stands as enacted in 2024.

1 Aug 2024 In force
AI Act enters into force

Regulation (EU) 2024/1689. Staggered application begins.

2 Feb 2025 Applied
Original Article 5 prohibitions · Article 4 AI literacy

Prohibited practices (social scoring, manipulation, untargeted scraping…) apply. AI literacy applied here too — the Omnibus later softens its wording (see below).

2 Aug 2025 Applied
GPAI model obligations · governance bodies

Technical documentation, copyright policy, training-data summaries for general-purpose AI providers. AI Office and AI Board operational.

2 Aug 2026 Unchanged
Article 50 transparency · GPAI enforcement · national authorities & penalties

Chatbot disclosure, synthetic-content marking for new systems, emotion-recognition and deepfake notices all apply. Commission can start fining GPAI providers. Member State penalty regimes and market surveillance apply. Only exception: Art. 50(2) marking for systems already on the market gets a short grace period.

2 Dec 2026 New
NCII / CSAM prohibition · Art. 50(2) marking for legacy systems

The Omnibus adds a new prohibited practice to Article 5: AI systems that generate non-consensual intimate imagery or CSAM ("nudifier" apps). Same day, the machine-readable marking duty catches up with generative systems placed on the market before 2 Aug 2026.

2 Aug 2026 → 2 Aug 2027 Moved
National AI regulatory sandboxes

Each Member State must have at least one sandbox operational — deadline pushed one year. An EU-level sandbox becomes possible. Sectoral delegated acts for Annex I systems are also due by this date.

2 Sep 2027 New
Commission post-market monitoring guidance + template

The implementing-act template is replaced by Commission guidance, including a template, due by this date.

2 Aug 2026 → 2 Dec 2027 Moved
High-risk obligations — Annex III stand-alone systems · FRIA

The full Chapter III regime for stand-alone high-risk systems (employment, credit, biometrics, education, essential services…) now applies from 2 Dec 2027 as a fixed date — no longer conditional on harmonised standards. The Article 27 fundamental rights impact assessment moves with it.

2 Aug 2027 → 2 Aug 2028 Moved
High-risk obligations — Annex I embedded systems

AI as a safety component of regulated products (medical devices, machinery-adjacent…). Note: the Machinery Regulation itself is carved out of the AI Act's scope by the Omnibus.

02 · What changed

The Omnibus at a glance

A deferral, not a dismantling: the risk-based architecture, the obligations and the penalty tiers all survive intact.

Moved

Later dates

  • Annex III high-risk + FRIA → 2 Dec 2027 (fixed)
  • Annex I embedded high-risk → 2 Aug 2028 (fixed)
  • National sandboxes → 2 Aug 2027
  • Art. 50(2) marking, legacy systems only → 2 Dec 2026
Unchanged

Still landing 2 Aug 2026

  • Art. 50 transparency for new systems — all four duties
  • GPAI enforcement — Commission fining powers begin
  • Penalties & market surveillance at national level
  • Penalty tiers — €35m/7% · €15m/3% · €7.5m/1.5% untouched
New

Added by the Omnibus

  • Art. 5 prohibition on NCII / CSAM generation — applies 2 Dec 2026, fines up to €35m/7%
  • Bias-detection data basis — special-category personal data may be processed for bias detection & correction, all AI systems, strict safeguards
  • Small mid-cap (SMC) category — SME-style simplifications extended
Softened / clarified

Same duty, lighter touch

  • Art. 4 AI literacy — now an obligation of effort ("support the development of"), not a guaranteed level. Not deleted.
  • Art. 6(3) registration — deletion was rejected; registration stays, with simplified content
  • GPAI supervision — AI Office gets exclusive competence over systems built on a provider's own GPAI model, with carve-outs
  • Machinery Regulation — exempted from AI Act scope; sectoral rules take over
Read this first

The new dates bind only once the Omnibus is published in the Official Journal (entry into force three days later, expected in July 2026). Until then, Regulation (EU) 2024/1689 as enacted remains the law. Use the deferral to build the file — not to pause it.

03 · Article 50 checker

Does the 2 August deadline apply to you?

Five questions against Article 50 as amended. Answers stay on this page — nothing is sent anywhere.

Art. 50(1) · Provider duty
Do you provide an AI system intended to interact directly with people?
Chatbots, voice assistants, conversational agents — internal or client-facing.
Art. 50(2) · Provider duty
Do you provide a system (incl. GPAI) that generates synthetic audio, image, video or text?
Generative tools whose outputs could pass as authentic content.
Art. 50(3) · Deployer duty
Do you deploy an emotion-recognition or biometric-categorisation system?
E.g. sentiment analysis on calls, categorising people by biometric data.
Art. 50(4) ¶1 · Deployer duty
Do you deploy a system that generates or manipulates deepfake image, audio or video content?
Content resembling real persons, places or events that could appear authentic.
Art. 50(4) ¶2 · Deployer duty
Do you publish AI-generated or AI-manipulated text to inform the public on matters of public interest?
News-style content, market commentary, public reports written by AI.

Answer all five questions to see your result.

Scope notes

Common exemptions apply (e.g. legally authorised law-enforcement use; assistive or standard-editing functions under 50(2); artistic/satirical works under 50(4); human editorial review for public-interest text). Information must be clear and distinguishable at first interaction or exposure. This is a screening aid, not legal advice.

04 · Sources

Where these dates come from

  • Regulation (EU) 2024/1689 (AI Act) — Articles 4, 5, 6, 27, 50, 113.
  • Digital Omnibus on AI — Commission proposal COM(2025) 836; provisional agreement 7 May 2026; Parliament endorsement 16 Jun 2026; Council adoption 29 Jun 2026. OJ reference to be added on publication.
  • Council of the EU press release, 29 Jun 2026 — fixed application dates and new prohibited practice.

Verify against the consolidated text on EUR-Lex once the amending regulation is published. This page reflects the state of play as of 11 July 2026.