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Since July 27, 2026, the AI Act has applied as amended by the Digital Omnibus (Regulation (EU) 2026/1744): Art. 4 has been revised, two prohibitions are added on December 2, 2026, and the high-risk obligations only begin in 2027 and 2028. This guide clarifies your role, explains risk levels, prohibitions, high-risk, transparency, and penalties with citations, and concludes with a checklist for the first steps.
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AI Act: Obligations and Deadlines at a Glance, Updated After the Digital Omnibus
- Topic
- AI in Business
- Format
- PDF, A4
- Length
- 9 pages
- Size
- 115 KB
- Updated
- Oct 25, 2026
- Sources
- 7
- Usage
- Redistribution in unchanged form permitted
WHO IT IS FOR
Who This
Is for.
Roles, risk levels, prohibitions, high-risk, transparency, AI literacy, penalties, and timeline of Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744.
- Executive management of companies that use or offer AI systems
- Compliance, legal, and data protection
- IT management that selects and operates AI tools
- HR departments that evaluate AI for recruitment or performance assessment
10 SECTIONS
What Is
Inside.
- 01
What it is about and what changed in 2026
The AI Act, the Digital Omnibus, and the situation in Austria
- 02
AI system and roles
What an AI system is and whether you are a provider or a deployer
- 03
The risk levels
Which obligations depend on the classification
- 04
Prohibited practices under Art. 5
What has been prohibited since February 2, 2025, and what is added from December 2, 2026
- 05
High-risk AI systems and deployer obligations
When a system is high-risk and what deployers then have to do
- 06
Transparency obligations under Art. 50
Label and inform, since August 2, 2026
- 07
AI literacy under the revised Art. 4
What has applied since July 27, 2026
- 08
Timeline after the Digital Omnibus
The key application dates and transition periods under Art. 113 and Art. 111
- 09
Penalties
Maximum amounts under Art. 99 and relief for smaller companies
- 10
First steps for your company
Checklist for taking stock, TOMORIS recommendation
EXCERPT
Timeline after the Digital Omnibus
| Date | What applies |
|---|---|
| Aug 1, 2024 | Entry into force of the AI Act |
| Feb 2, 2025 | Chapters I and II: general provisions, AI literacy, prohibitions under Art. 5(1)(a) to (h) |
| Aug 2, 2025 | General-purpose AI models, governance, penalties (excluding Art. 101) |
| Jul 27, 2026 | Regulation (EU) 2026/1744 in force: Art. 4 revised; amendments to other legal acts (Art. 102 to 110) apply |
| Aug 2, 2026 | General date of application, including Art. 50 and fines under Art. 101 |
| Dec 2, 2026 | Prohibitions ba and bb including Art. 5(1a) and (1b); Art. 50(2) for older systems (Art. 111(4)) |
| Aug 2, 2027 | AI models already placed on the market before Aug 2, 2025 (Art. 111(3)) |
| Dec 2, 2027 | Obligations for high-risk AI systems under Annex III |
| Aug 2, 2028 | Obligations for high-risk AI systems under Annex I |
| Aug 2, 2030 | Deadline for high-risk AI systems intended to be used by public authorities |
| Dec 31, 2030 | AI systems in large-scale IT systems under Annex X (Art. 111(1)) |
SOURCES
Supported
by Sources.
- Regulation (EU) 2024/1689 (AI Act), consolidated version of July 27, 2026, EUR-Lex (opens in a new tab)Art. 2 to 6, 25 to 27, 50, 99, 111, 113, Annex III, accessed October 25, 2026
- Regulation (EU) 2026/1744 (Digital Omnibus Regulation on AI), OJ L of July 24, 2026 (opens in a new tab)Art. 1(5), (7), (38) to (40), Art. 4 entry into force, accessed October 25, 2026
- RTR AI Service Center: Timeline and implementation of the AI Act (opens in a new tab)Deadlines after the Digital Omnibus, accessed October 25, 2026
- RTR AI Service Center: Frequently asked questions (opens in a new tab)Tasks of the AI Service Center, national implementation of competences, accessed October 25, 2026
- European Commission: Guidelines on prohibited AI practices (February 4, 2025) (opens in a new tab)Description and status of the guidelines, accessed October 25, 2026
- European Commission: Guidelines on the definition of an AI system (February 6, 2025) (opens in a new tab)Description of the guidelines, accessed October 25, 2026
- European Commission: Market Surveillance Authorities under the AI Act (opens in a new tab)Single points of contact of the Member States, page dated September 7, 2026, accessed October 25, 2026
This guide provides an overview and does not replace legal advice. The statutory text in its current version is authoritative, in particular the AI Act together with Regulation (EU) 2026/1744; classification depends on the individual case.
TOOLBOX
Explore
Further.
AI usage policy
Template for permitted tools, data classes, labeling, and AI literacy in the company.
Learn MoreEU AI Act
The AI Act explained briefly, with deadlines after the 2026 Digital Omnibus.
Learn MoreAI literacy
What AI literacy means and which measures the AI Act requires from providers and deployers.
Learn MoreAI consulting
TOMORIS examines tasks, data, and processes and develops prioritized AI use cases.
Learn More
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YOUR NEXT STEP
From Paper
to Practice.
We review with you what is already implemented in your environment and put the rest into practice: as a project with EXPERTS or as ongoing operations with GRID.