AI Act Omnibus Agreed: 2 December 2027 Deadline Confirmed
The deal that fell apart on 29 April has been agreed on. At the resumed trilogue, Parliament, Council, and Commission agreed the AI Act Omnibus text. The 2 December 2027 application date for Annex III high-risk obligations is no longer a proposal. It is the new deadline.
If you’ve been tracking this since the Parliament’s vote in March, the headline dates are unchanged from then. What’s different is that the political risk that hung over the collapsed April trilogue is gone. The sectoral carve-out question that broke the room in April has been settled with a compromise, and the dates have held.
What’s confirmed
| Obligation | Original deadline | Confirmed deadline |
|---|---|---|
| Annex III high-risk systems | 2 Aug 2026 | 2 Dec 2027 |
| Annex I sectoral safety-component systems | 2 Aug 2027 | 2 Aug 2028 |
| Article 50 watermarking for synthetic content | 2 Aug 2026 | 2 Nov 2026 |
The Parliament’s nudifier prohibition survives in the agreed text. The SME flexibility extension to small mid-cap enterprises survives. The narrow provision permitting personal data processing for bias detection and correction survives.
What still needs to happen
The trilogue agreement is the political deal. The mechanical steps remain: lawyer-linguist review across 24 languages, plenary vote in Parliament, formal Council adoption, signature by the two Presidents, and publication in the Official Journal. None of these are expected to produce surprises — the substantive disagreement was the trilogue itself, and it’s resolved. Publication should land well before 2 August 2026, which is the only date that mattered for the headroom to mean anything.
Until OJ publication, the original text technically governs. But national competent authorities are not going to enforce a 2 August 2026 deadline against companies relying on a confirmed delay queued for adoption. The enforcement risk that existed two weeks ago has effectively collapsed.
What this changes for compliance teams
Less than you’d think.
If you paused after the March vote and then scrambled after 29 April, you’re still behind where you were on 1 April. The 16 months you’ve gained on Annex III obligations don’t refund the momentum you lost.
If you kept working through the April uncertainty, you now have headroom rather than a crisis. Use it for risk management depth under Article 9, technical documentation rigour under Annex IV, and first-audit preparation — not for stopping.
Article 50 transparency obligations still apply from 2 November 2026. That’s roughly six months of engineering, not sixteen. Synthetic-content marking, channel-level AI disclosure, and biometric notification need to be design-complete by mid-2026 regardless of what just happened in Brussels.
The deadline moved. The work didn’t.
This article is part of the ComplyDrive EU AI Act Knowledge Base. ComplyDrive publishes an EU AI Act Compliance Checklist and Sample Documentation — 47 checklist items across 5 phases, with 9 complete example compliance documents. Details at complydrive.ai.