Each deadline in detail
2 February 2025: Banned practices
Certain uses of AI are prohibited outright, such as social scoring, manipulative techniques, and emotion recognition in the workplace or in education.
Art. 5
2 August 2025: General-purpose AI models
Obligations for the companies that build general-purpose AI models. Most SMEs use these models rather than build them.
Chapter V
2 August 2026: Transparency duties
People must be told when they are dealing with AI, when content is AI-generated or manipulated, and when emotion recognition or biometric categorisation is used on them.
Art. 50
2 December 2027: High-risk uses: hiring, credit and more
Full obligations for AI used in high-stakes decisions about people: recruitment and employment, creditworthiness, insurance pricing, education and access to essential services. Moved from August 2026 by the Digital Omnibus.
Annex III
2 August 2028: AI in regulated products
High-risk AI built into products already covered by EU safety law, such as machinery, medical devices and vehicles.
Annex I
What the Digital Omnibus changed
The Digital Omnibus on AI was agreed on 7 May 2026 and adopted in June 2026. Its main changes to the timeline:
- High-risk AI in Annex III (employment, credit, insurance, education, essential services) moved from 2 August 2026 to 2 December 2027.
- High-risk AI in regulated products (Annex I) moved from 2 August 2027 to 2 August 2028.
- Transparency duties under Article 50 kept their 2 August 2026 date. Generative AI systems already on the market before that date have until 2 December 2026 to add machine-readable marking of AI-generated content (Art. 50(2)).
- A new ban on AI that generates non-consensual intimate imagery or child sexual abuse material, with a transition to 2 December 2026.
- AI literacy (Art. 4) became a duty to support staff literacy rather than to ensure a set level.
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