European Union delays its high-risk artificial intelligence obligations by sixteen months

2026-05-13EU Policy

Digital AI Omnibus — provisional political agreement 6 May 2026, confirmed by Member State representatives 13 May 2026, amending Regulation (EU) 2024/1689 (the Artificial Intelligence Act)

Obligations for stand-alone high-risk artificial intelligence systems listed in Annex III move from 2 August 2026 to 2 December 2027. Obligations for artificial intelligence embedded in regulated products under Annex I move from 2 August 2027 to 2 August 2028. The core transparency obligations under Article 50 still take effect on 2 August 2026, with a watermarking grace period for existing systems running to 2 December 2026. The Article 5 prohibitions were expanded, and the deadline for Member States to establish regulatory sandboxes moved to 2 August 2027.

What it changesThis is a compliance timetable rather than a patent rule, and it still moves filing dates. A client who was holding a European launch until the high-risk obligations landed now has sixteen more months of roadmap. Filings have to be on file covering what ships, so the launch date moving moves the filing plan with it.

← All recent developments · Full archive

This is general information about a published decision, agency guidance or piece of legislation. It is not legal advice and does not create an attorney-client relationship. Items concerning offices outside the United States are reported for information only and are not counsel on the law of those countries.