may 7 2026 - the eu council and parliament agreed to move high-risk obligations under annex iii from aug 2 2026 to dec 2 2027. annex i (ai embedded in regulated products) moves to aug 2 2028.
every buyer i talked to today asked the same question - do i still need to act now.
the answer is yes, and the reason isn't legal, it's operational.
what the omnibus actually delayed
the deadline to be compliant
the fines if you're not
what the omnibus did not delay
article 12 logs (immutable, 6mo retention, traceable to a specific input/output)
the conformity assessment paperwork
the post-market monitoring plan
the procurement teams that already ask for ai act readiness in vendor questionnaires
why the engineering still ships this quarter
german + french procurement teams started asking for ai act readiness 9 months ago. that didn't move.…