📝 Update of 6 August 2026
This article was published before the adoption of Regulation (EU) 2026/1744 of 24 July 2026 ("Digital Omnibus on AI"), which amended the application timeline of Regulation (EU) 2024/1689.
Obligations for Annex III high-risk AI systems now apply from 2 December 2027 (instead of 2 August 2026), while Annex I obligations now apply from 2 August 2028 (instead of 2 August 2027). The deadlines mentioned below have been updated accordingly. The Article 50 transparency obligations, however, have applied since 2 August 2026.
When this article was first published, the European Commission had rejected calls to suspend the AI Act timetable. Since then, Regulation (EU) 2026/1744 ("Digital Omnibus on AI") has postponed the application dates for high-risk AI obligations.
This article reflects the debate that took place before those legislative changes were adopted. The “Stop the Clock” initiative, signed by over 150 companies (including some of the world’s largest tech players), argued that high regulatory uncertainty and insufficient practical guidance made it increasingly difficult for companies to prepare in time. For instance, originally intended for release on May 2, 2025, the General-Purpose Code of Practice has been delayed.
Therefore, they requested at least a one-year pause on enforcement. But the Commission spokesperson Thomas Regnier told a press conference “I've seen, indeed, a lot of reporting, a lot of letters and a lot of things being said on the AI Act. Let me be as clear as possible, there is no stop the clock. There is no grace period. There is no pause.” (Reuters)
At the time, this statement accurately reflected the Commission's position. However, the legislative process ultimately resulted in the adoption of Regulation (EU) 2026/1744, which postponed the application dates for high-risk AI obligations while leaving other milestones, such as the GPAI obligations and Article 50 transparency requirements, unchanged.
So what does this mean today? General-purpose AI model obligations have applied since 2 August 2025, while the transparency obligations under Article 50 have applied since 2 August 2026. Following Regulation (EU) 2026/1744, obligations for Annex III high-risk AI systems now apply from 2 December 2027, and those for Annex I systems from 2 August 2028. Meanwhile, you should already be deploying a proper governance framework: build internal templates for AI-specific reviews, define how ethical principles (like fairness, accountability, transparency) are put into practice, map your AI systems whether internally developed or purchased, rate their risks, & clarifying ownerhsip.Remember, AI governance is not a static policy.
🎯 At Dastra, we continue to see this as a clear signal: organisations should use the additional time introduced by the Digital Omnibus to strengthen their AI governance frameworks rather than postpone their compliance efforts. It’s time to embed AI risk management into your compliance DNA, just like we learned to do with the GDPR.