Written by: Haim Ravia, Dotan Hammer
On July 27, 2026 the Digital Omnibus on AI entered into force, amending the EU AI Act. The Omnibus is the product of a legislative process that began with the European Commission’s November 2025 proposal, followed by political agreement between the Parliament and Council on May 7, 2026, and formal adoption on July 8, 2026.
The Omnibus introduces targeted amendments designed to simplify the implementation of the EU AI Act while maintaining its fundamental rights protections. Among the most significant changes are revised compliance timelines for high-risk AI systems. Under the original AI Act, the rules for high-risk systems listed in Annex III were due to apply from August 2, 2026. The Omnibus replaces that date with a conditional mechanism: high-risk rules will apply six months after the Commission confirms that adequate compliance support measures — including harmonized standards and guidelines — are available, or by December 2, 2027 for Annex III systems and August 2, 2028 for Annex I systems, whichever comes first. This addresses the acknowledged absence of finalized harmonized standards and the delays in Member States’ designation of national competent authorities.
The Omnibus also introduces a new prohibition on AI systems that generate non-consensual intimate imagery — so-called “nudification” apps — adding this practice to the list of prohibited AI systems under Article 5 of the AI Act. On AI literacy, the Omnibus retains the obligation on providers and deployers to ensure a sufficient level of AI literacy among their staff, reversing the Commission’s initial proposal to make this voluntary. However, the obligation does not guarantee a specific level of AI literacy for any individual.
Other amendments include clarifications to the regulatory sandbox framework, including requirements for the involvement of national data protection authorities and the EDPB where sandboxes involve the processing of personal data, and refinements to the rules on real-world testing of high-risk AI systems. The Omnibus also adjusts the interplay between the AI Act and sectoral Union harmonisation legislation, particularly in the areas of aviation safety and machinery.
Click here to read the EU Commission’s announcement: AI Omnibus enters into force.
Click here to read Regulation (EU) 2026/1744 (the Digital Omnibus on AI).
