The European Union's Digital Omnibus package granted significant delays to high-risk AI system requirements under the AI Act, but the framework's transparency obligations remain largely intact. High-risk systems under Annex III covering employment, creditworthiness, education, and essential services moved from August 2, 2026 to December 2, 2027, while high-risk systems embedded in regulated products moved to August 2, 2028.
The reprieve did not extend to the Act's disclosure rules. Article 50 of the AI Act still applies from August 2, 2026, requiring providers and deployers to implement five distinct disclosure duties. Among them, providers must ensure synthetic outputs are marked in a machine-readable format and detectable as artificially generated or manipulated.
The result is a split compliance calendar: softer deadlines for the highest-risk applications, but no such mercy for the basic disclosure obligations that shape how people encounter synthetic media. The Omnibus left most of the Act's transparency obligations exactly where they were.