The AI Act (Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024) entered into force on 1 August 2024, marking the beginning of a phased application of its provisions.
Following the adoption of the AI Omnibus (Regulation (EU) 2026/1744 of 24 July 2026), the implementation timeline and certain substantive provisions of the AI Act have been amended as part of the European Union's broader simplification agenda, which aims to streamline implementation, improve legal certainty and reduce unnecessary compliance burdens while preserving the Regulation's core objectives.
What has changed?
- Updated application dates: The application of several AI Act obligations has been postponed. The rules applicable to stand-alone high-risk AI systems will now apply from 2 December 2027, while the rules for high-risk AI systems embedded in products or constituting safety components of products will apply from 2 August 2028. The deadline for Member States to establish AI Regulatory Sandboxes has also been postponed to 2 August 2027;
- Transparency obligations: The application of the providers' marking and detection obligations relating to AI-generated content and deepfakes has been postponed until 2 December 2026. However, the transparency obligations applicable to deployers of AI-generated content, deepfakes, emotion recognition and biometric categorisation systems, as well as the obligations applicable to providers of AI systems that interact directly with natural persons, continue to apply from 2 August 2026;
- New prohibited AI practice: The AI Omnibus expressly prohibits AI practices involving the generation of non-consensual intimate content and AI-generated child sexual abuse material (CSAM);
- Bias detection: The requirement of strict necessity for the processing of special categories of personal data for the purposes of detecting and correcting bias in AI systems has been reinstated;
- Sector-specific legislation: Explicit reference to guidance on the interaction between the AI Act and harmonised sectoral legislation, including legislation on medical devices, machinery and toys, helping to avoid duplicative compliance requirements;
- AI Regulatory Sandboxes: The deadline for Member States to establish AI Regulatory Sandboxes has been extended until 2 August 2027, providing additional time to develop controlled testing environments for innovative AI systems;
- AI Office competences: The supervisory role of the AI Office over AI systems based on general-purpose AI models has been clarified, while confirming the areas that remain within the competence of national authorities;
- European Commission guidance: The European Commission is required to publish guidance to support providers and deployers of high-risk AI systems subject to harmonised sectoral legislation, promoting a more consistent and practical application of the AI Act across sectors.
This landmark Regulation remains the world's first comprehensive legal framework governing artificial intelligence. It seeks to foster the development and deployment of trustworthy AI, safeguard fundamental rights, and position the European Union as the global benchmark for AI regulation.
To facilitate a clearer and more comprehensive understanding of the Regulation, VdA has prepared an updated User-Friendly AI Act, incorporating the AI Omnibus amendments into a single, consolidated text.
What´s new in this version?
- The Digital Omnibus amendments have been integrated into the text;
- New and amended provisions are highlighted in green;
- Articles, Recitals and Annexes remain integrated and cross-referenced;
- The implementation timeline has been updated;
- References to other relevant EU legislation continue to illustrate the wider legal framework.
We hope this updated User-Friendly AI Act serves as a practical resource for legal, compliance, governance, policy and technology teams navigating the legal, ethical and technical challenges of artificial intelligence. Should you have any questions regarding the AI Act or its implementation, our team remains at your disposal.
