New application dates for high-risk AI system rules

Following the publication of the European Commission’s proposal for a Regulation as regards the simplification of the implementation of harmonised rules on artificial intelligence, the so-called Digital Omnibus on AI, in November 2025, the proposal has been under examination by the European Parliament and the Council of the EU. The Commission proposed to link the application of Artificial Intelligence Act (AI Act) requirements for high-risk systems (Annex III AI systems) to the availability of harmonised standards and common specifications. Once these are in place, a transition period would begin with a final backstop date by 2 December 2027 for Annex III high-risk systems.

The AI Act sets out that AI systems referred to in Annex III shall be considered to be high-risk. Annex III includes, amongst others, AI systems intended to be used to evaluate the creditworthiness of natural persons or establish their credit score, except for AI systems used for the purpose of detecting financial fraud. The AI Act provisions that requirements for high-risk AI systems would start to apply on 2 August 2026. 

The European Parliament and the Council of the EU have now reached an agreement on the final legal text of the Digital Omnibus on AI, which was formally adopted by the Parliament’s plenary and by the EU Ministers in June 2026. The adopted text introduces new fixed dates for the application of the high-risk AI requirements. Instead of 2 August 2026, the AI Act provisions for high-risk AI systems will apply from 2 December 2027 for stand-alone high-risk AI systems, and from 2 August 2028 for high-risk AI systems embedded in products. 

The final text of the Regulation will now be published in the EU Official Journal and enter into force.