DepthThe conclusion and your first steps
Direct answer
What did the Digital Omnibus shift and what still applies as planned?
You describe: You want the current timeline: which obligations were postponed and which deadlines stand. Likely role: every role.
This applies now
- Article 50: transparencyApplicable
- Article 4: AI literacyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
- Article 27: FRIAfrom 2 December 2027
Regulation (EU) 2026/1744 is in force since 27 July 2026: high-risk Annex III moves to 2 December 2027 and Annex I to 2 August 2028. Not shifted: the prohibited practices, Article 4, Article 50 and GPAI enforcement. Next date: 2 December 2026.
Your first actions
- Justify the Article 6(3) exception against each individual condition. Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making.
- Map the affected groups and their specific risks of harm. Name the categories of natural persons and groups likely to be affected by the use in this specific context, and work out the specific risks of harm per category, using the information the provider supplied under Article 13.
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situation