AI Omnibus adopted: what you need to know

On 8 July 2026, the European Union has formally adopted the AI Omnibus Regulation (EU) 2026/1744 (the “AI Omnibus”), effective as from 27 July 2026. The AI Omnibus introduces targeted amendments to the AI Act aimed at reducing compliance burdens while preserving its core regulatory framework.

Extended timelines, further SME relief and new prohibitions

The most significant changes to the AI Act can be summarized as follows:

• Extension for stand-alone high-risk AI systems: the deadline for providers of high-risk AI systems listed in Annex III to comply with the obligations set forth in Chapter III, Sections 1, 2 and 3 of the AI Act is postponed from 2 August 2026 to 2 December 2027.

• Extension for AI systems embedded in regulated products: for AI systems intended to be used as a safety component of a regulated product as set forth in Annex I of the AI Act, the obligations set forth in Chapter III, Sections 1, 2 and 3 of the AI Act are deferred until 2 August 2028.

• Delayed watermarking requirement: the obligation to apply machine-readable watermarking for AI-generated content (article 50.2 of the AI Act) is postponed until 2 December 2026.

• Broader SME scope: the simplified obligations under the AI Act for SMEs are expanded to small mid-cap companies, allowing them to benefit from simplified compliance requirements and additional support measures.

• New prohibitions: the AI Omnibus introduces a clear ban on AI-systems that create explicit material of identifiable persons or that generate CSAM.

• Processing of special categories of personal data: the legal basis for processing special categories of personal data for bias detection and correction is, in certain circumstances, extended to providers and deployers of all AI systems and models, rather than being limited to high-risk AI systems.

• AI literacy: the obligation for providers and deployers to “take measures to ensure a sufficient level of AI literacy” of their staff has been revised to an obligation to “take measures to support the development of AI literacy”, making the obligation more concrete while also reducing its stringency.

Less extensive simplification than initially proposed

While the final AI Omnibus Regulation introduces some simplifications, these changes are less extensive than those originally proposed by the Commission. Several envisaged measures — such as broader exemptions from technical documentation, further streamlining in conformity assessment requirements, and wider simplifications for high-risk AI providers and deployers — were not retained

2 August 2026 remains an important milestone

Importantly, businesses should not interpret the AI Omnibus as a general delay of the AI Act. 2 August 2026 remains a key compliance milestone. Except for the amendments referred to above and the provisions of the AI Act that had already entered into force, most of the obligations under the AI Act still apply as from 2 August 2026.

In particular, the transparency obligations under Article 50 of the AI Act, applicable to both providers and deployers of AI systems,  entered into force as scheduled on 2 August 2026. These obligations require, among others, that users are informed when interacting with AI systems such as chatbots, and that AI-generated or manipulated content is appropriately disclosed. Only a limited exception applies to the machine-readable marking requirement for certain synthetic content generated by AI systems that were already placed on the market before 2 August 2026, for which compliance is postponed until 2 December 2026.

Part of a broader (but not yet adopted) Digital Omnibus agenda

The AI Omnibus forms part of the European Commission’s broader Digital Omnibus initiative, which seeks to simplify several pieces of EU digital legislation and improve consistency across the digital regulatory framework. In addition to the AI Act, the wider package includes proposed amendments to instruments such as the Data Act, GDPR-related legislation and other digital rules. Unlike the AI Omnibus Regulation, these broader legislative proposals are still under negotiation and have not yet been adopted.

Attention points for your business

• Identify and assess AI systems used: identify the AI systems that are commercialized or used within your company, assess your role (provider or deployer) and whether the relevant obligations set forth in the AI Act are complied with.

• Put in place an AI compliance plan and policy: create and implement a plan to comply with the AI obligations applicable to your organization, create a policy to ensure compliance by your employees and to avoid use within your organization of unverified AI systems. Assess, taking into account the nature of the AI systems used, the actions to be taken to support the development of AI literacy and implement a plan to support development of AI literacy on an ongoing basis.

• Document compliance: document the efforts made by your organization to comply with the AI Act (among others as to periodical assessments of AI systems used or AI systems developed, of internal compliance with the AI policy, as to periodical efforts to support the development of AI literacy, etc.).

As a law firm specializing in corporate law, tax law and commercial law, De Langhe Attorneys is closely monitoring the rapid developments surrounding the AI Act and the new AI Omnibus. We understand that this legalization has a direct impact on our clients’ commercial and operational activities and are keen to work proactively with you.

Please feel free to contact us for a no-obligation consultation. We’ll work with you, taking into account both the legal and business realities, to support your company.

Jan Van Camp and Tibo Truyens
De Langhe Attorneys