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□ index.mdAI Act: postponed? Not the way you think.
The Digital Omnibus (EU) 2026/1744 has pushed high-risk obligations back to 2027–2028. But since 2 August 2026, authorities have held their sanctioning powers, and transparency is mandatory. “It's been postponed” is the most expensive phrase in your boardroom.
Verdict
the essentials in 10 seconds3 rowsACTIVEArticle 50 transparency, sanctioning powers, regulatory sandboxes.NOW
POSTPONEDAnnex III high risk → Dec 2027 · Annex I → Aug 2028. Postponement ≠ exemption.OMNIBUS
NEW2 practices added to the blacklist, maximum sanction tier.DEC 2026
Timeline
what's due, and when6 rows02.02.2025Prohibited practices + AI literacy. Already enforceable, often overlooked.IN FORCE
02.08.2025GPAI models, unchanged, unaffected by the omnibus.IN FORCE
02.08.2026Sanctions + Article 50 transparency. Authorities operational.YOU ARE HERE
02.12.2026New prohibitions + end of the marking window for existing AI content stock.D−107
02.12.2027Annex III high risk: HR, scoring, education, critical infrastructure.MOVED
02.08.2028Annex I high risk: AI embedded in regulated products.MOVED
Enforceable now
the real scope of risk5 rowsart-50User information: anyone facing an AI must be told so.ENFORCEABLE
marquageIdentifiable generated content: published texts, images, videos.ENFORCEABLE
contrôleAuthorities' powers: investigations, orders, fines.ENFORCEABLE
littératieStaff training: the number-one blind spot for SMEs and mid-caps for the past 18 months.ENFORCEABLE
gpaiModel regime: in force since August 2025.ENFORCEABLE
€35 MOR 7% OF GLOBAL TURNOVER
Maximum tier, active since 2 August. Postponing high risk has disarmed neither the authorities nor the fines on what remains enforceable.
Action Plan
to launch this week5 rows01Inventory actual AI usage: including embedded SaaS and Shadow AI.WITHIN 10 DAYS
02Clear notice on every chatbot: internal as well as external.
03Mark published content, new: immediate, existing stock: window until Dec 2026.DEC 2026
04Document the training: a written record is worth more than an intention.
05Plan for high risk: Dec 2027 is coming fast. No panic, no shelving it.
Go deeper
fundamentals, in Learn2 linksDon't know what's running in your organisation? Shadow AI Sentinel: 90 days to map your AI usage, declared and undeclared.
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