The Omnibus moved 2 August to December 2027. Your procurement will not wait
The high-risk obligation deadline slipped by 16 months. The enterprise client's question did not move a single day.
On 7 May 2026 the provisional Digital Omnibus agreement on AI was reached, the first amendments to the AI Act since its adoption in June 2024. Its most-discussed effect is a postponement of deadlines, and it is worth understanding exactly what moved.
What was postponed and what was not
- Annex III high-risk systems (employment, education, credit, critical infrastructure, etc.): from 2 August 2026 to 2 December 2027, about 16 months.
- Annex I high-risk systems (regulated products): from 2 August 2027 to 2 August 2028.
- Most transparency obligations under Article 50 still apply from August 2026, unchanged.
The reason for the delay is not a shift in political stance but something more prosaic: the harmonised conformity standards, the ones that let you demonstrate compliance in a standardised way, were not going to be ready in time. Without that technical standard, demanding full conformity meant asking companies to prove something against a yardstick that did not yet exist.
Deferred obligation is not deferred demand
Here is the most expensive misreading. The fact that the legal obligation's date has moved to December 2027 does not move the date on which your client starts asking. A large company's procurement questionnaire already asks today about your risk classification, your documentation and your management of AI suppliers. Do not confuse "deferred obligation" with "deferred demand": they are two different clocks, and only one has been stopped.
For anyone selling hiring software to large accounts, the conclusion is direct. The window to December 2027 is not time to do nothing, but room to arrive prepared for a purchasing conversation that is already happening.