The EU AI Act's high-risk deadline moved to December 2027 — and we got this wrong
The AI Omnibus, in force since 27 July 2026, pushes stand-alone Annex III high-risk systems — credit scoring, recruitment, education, law enforcement — to 2 December 2027, and embedded Annex I systems to 2 August 2028. What activated on 2 August 2026 was GPAI and transparency enforcement, not the high-risk annex.
Correction. This site published an article on 13 August stating that the Act's high-risk obligations had reached credit scoring and insurance pricing this month. That was wrong, the article has been corrected, and this piece is the accurate account.
The instrument that moved the date is the AI Omnibus. It was proposed on 19 November 2025, reached political agreement between Parliament and Council on 7 May 2026, was finally approved on 29 June, and entered into force on 27 July 2026. It resets two dates: 2 December 2027 for stand-alone Annex III systems, and 2 August 2028 for high-risk AI embedded in regulated products under Annex I — medical devices, machinery, vehicles.
Annex III is the list that matters commercially: recruitment, creditworthiness assessment, education access, law enforcement, border control. Annex I is the product-safety route. Both moved; neither was repealed.
What did happen on 2 August 2026 is real and separate. The Commission's AI Office and national authorities began enforcing the GPAI obligations and the new transparency requirements. Powers to compel access to a model, and penalties of up to €15m or 3% of worldwide turnover for GPAI breaches, are live now.
The stated reason for the delay is that the supporting technical standards were not ready — which is an admission worth reading carefully. A conformity-assessment regime cannot bind before the harmonised standards defining conformity exist. The co-legislators paired the extension with an explicit expectation that preparation is already underway, because eighteen months is what it takes to do the documentation, not a reprieve from doing it.
Council of the EU — Artificial intelligence: Council gives final green light to simplify and streamline rules → · Pinsent Masons — Law delaying EU's 'high-risk' AI rules finalised → · Gibson Dunn — EU AI Act Omnibus Agreement — Postponed High-Risk Deadlines and Other Key Changes →