EU AI Act Omnibus introduces two new prohibitions — non-consensual intimate AI material and CSAM generation banned in addition to Annex III deferrals
The May 7 Digital Omnibus on AI agreement introduces two new prohibited AI-related practices alongside the High-Risk AI Systems timeline extensions: the use of AI systems to generate or manipulate non-consensual intimate material, and AI-generated child sexual abuse material (CSAM). The new prohibitions reflect a substantive policy expansion focused on the most harmful misuse categories rather than only timeline accommodation.
The substantive-prohibition piece is the operational expansion. The May 7 Digital Omnibus on AI is most commonly framed in industry coverage as a regulatory-timeline-relief package — the 16-month deferral on Annex III HRAIS obligations and the 1-year extension on Annex I product-regulated systems. But the same package adds two new prohibited AI practices at full Article 5 enforcement: AI-generated non-consensual intimate material (deepfake-pornography misuse), and AI-generated CSAM. These prohibitions are not timeline-relief but structural-scope expansion of the AI Act's prohibited-practice surface.
The competitive consequence is the deployment-compliance bifurcation. The Annex III HRAIS timeline deferral to December 2027 gives industry operational runway for the broadest compliance category. The two new prohibitions are immediately enforceable on the same package and have no runway: AI deployers must implement non-consensual-intimate-material and CSAM-generation defenses now, not in 18 months. The procurement consequence for video-generation, image-generation, and multimodal-system vendors is that the prohibition-defense surface is now legally specified rather than ethically optional. The Gemini Omni Flash any-input multimodal rollout ships into this regulatory context directly.
Consilium — Artificial Intelligence Council and Parliament agree simplify streamline rules May 7 → · Euronews — EU simplified toughest AI law what changed why matters May 21 → · Inside Global Tech — EU AI Act Update Timeline Relief Targeted Simplification New Prohibitions May 28 →