The AI Act is delayed but already biting
„The Digital Omnibus only extended deadlines for high-risk items; transparency and GPAI rules remain in force, and the AI Office is already requesting information from companies, so compliance cannot be postponed.”
Counter-narrative
The delay indicates that fundamental regulatory problems remain unresolved. In many member states, enforcement authorities are missing, implementation is lagging, and Big Tech is lobbying to reshape the regulation. This view is held by Big Tech players and some critical analysts.
Carriers
European Commission and AI Office, International law firms and professional analyses, consultants, Professional and news media (e.g., Politico), national AI authorities
Analysis
The narrative's twofold message is that a delay is not an exemption, so preparation must be funded now. It is fed by the enforcement phase that began on 2 August, the AI Office's information requests and the first harmonised standard. It gives consultants and law firms compliance work, and gives the Commission an argument that voluntary commitments do not replace mandatory compliance. The weak point is that the real enforcement test is still to come. Many member states lack an authority, the compliance advantage tied to the first standard is delayed, and the trilogue may bring further amendments.
What's at stake: Whether binding EU regulation can remain credible after the postponements.
Narrative sub-threads
Omnibus: only high-risk items delayed
Regulation 2026/1744 (Digital Omnibus on AI) entered into force on July 27, delaying key obligations for high-risk systems to December 2027 and August 2028; for AI-based medical devices, the deadline is August 2, 2028. This is not a general delay: transparency obligations under Article 50, AI proficiency, and GPAI oversight did not slip.
This branch is based on legislative events and the deadline calendar; the evidence is analysts' interpretation of the amendment, not regulatory action.
→ lasting · evidence: strongArticle 50 labelling requirements take sharper shape
Since August 2, the transparency rules of Article 50 apply: chatbots must disclose that they are AI, and deepfakes and many kinds of AI-generated content must be labeled. Providers are responding with watermarking, but corporate readiness is lacking: a Dutch survey found that only 14 out of 100 companies clearly label their chatbot, and according to Economx, most Hungarian companies do not yet know what to prepare for.
Corporate and provider adaptation is at the center, including watermarking by Anthropic and OpenAI and a Dutch survey showing that 14 out of 100 companies label their chatbot.
↗ rising · evidence: strongThe AI Office is already requesting information
From August 2, the Commission may act as a central supervisor against GPAI providers, imposing fines of up to €15 million or 3% of turnover. The AI Office has begun requesting information: reports indicate it sent security and compliance inquiries to more than 30 AI companies, and requested information from OpenAI and Anthropic regarding incidents involving agents. Meanwhile, many member states have not yet established the authorities responsible for enforcement.
The actor here is EU supervision, and the mechanism is the specific regulatory step: information requests, the GPAI code, and reporting channels, with a fine cap of 15 million euros or 3 percent.
↗ rising · evidence: moderateStandards and compliance presumption
The first European standard linked to the AI Act, EN 18286:2026, is ready. Published in August, it entered the EU Official Journal in October as the first harmonized standard. Upon approval, presumption of conformity was not yet attached, but since gaining harmonized status, it can provide presumption of conformity for relevant requirements.
This strand follows technical standardization, not legislation or regulatory action; delays in standards were also one of the main reasons for the postponement.
↘ fading · evidence: mediumThe Hungarian AI regulatory framework takes shape
Hungary has adopted an AI law and a government decree that allow fines of up to 5.7 billion forints for high-risk AI systems. According to the August 31 issue of the Hungarian Gazette (Magyar Közlöny), AI market surveillance was transferred to the Minister of Science and Technology, and according to Jogászvilág, the Deputy State Secretariat for Artificial Intelligence has been established.
It shows the construction of the domestic institutional and competence framework: a law, the Hungarian Gazette, a ministry organization, and the Artificial Intelligence Office, not EU-level action.
Sub-thread stories
Omnibus: only high-risk items delayed
Digital Omnibus becomes law, delaying high-risk AI deadlinescompliance specialistThe preparation timeline must be adjusted, but the prohibitions and the rules for general-purpose models have not been postponed.corporate lawyerThe timing of obligations in contractual compliance commitments must be renegotiated in light of the amendment.lawyerClients should be told that the postponement does not cover every obligation.EU digital omnibus in force: high-risk AI rules pushed back to December 2027corporate lawyerContract and compliance projects for high-risk AI systems must be rescheduled to the new deadlines.compliance specialistThe compliance roadmap must be updated, separating postponed obligations from those that are already live.lawyerAI Act advice to clients must be based on the new deadlines and the newly introduced prohibition.Digital Omnibus pushes AI Act high-risk deadlines to 2027–2028compliance specialistCompliance plans must be redrawn obligation by obligation, because only the deadline for high-risk systems has moved.corporate lawyerReferences to deadlines and provider commitments in contracts must be reviewed.lawyerClients must be told precisely which obligation has been postponed and which has not.EU AI Act: Digital Omnibus delays high-risk deadline, but obligations remain in forcecompliance specialistDespite the delay, obligations already in force (such as transparency) must be met on time, and preparation for high-risk systems must continue.corporate lawyerThe roles under the AI Act (provider, deployer) and the Annex III classification need to be reviewed, including for contracts.lawyerClients need to be told what has been postponed and what remains in force.AI Omnibus shifts AI Act deadlines; critics say core problems remaincompliance specialistCompliance timelines must be aligned with the new deadlines, and sector-specific deviations tracked separately.corporate lawyerThe omnibus introduces no separate penalty, so sanction risk should be estimated under the original provisions of the AI Act.Digital Omnibus is the first substantive amendment to the EU AI Actcompliance specialistThe amendment may affect the compliance timeline and priorities, so it should be monitored.corporate lawyerContractual compliance clauses should be reviewed in light of the amendments.Digital Omnibus: EU to delay application of AI Act high-risk rulescompliance specialistCompliance roadmaps for high-risk systems must be re-planned around the amended deadlines, building in the uncertainty.corporate lawyerDelivery deadlines in AI procurement and supplier contracts should be aligned with the amended regulatory timetable.lawyerClients should be told that the delay is still part of a legislative process and is not final.EU AI Act after the omnibus: high-risk rules slip, transparency obligations do notcompliance specialistThe focus now should be on Article 50 labelling and GPAI obligations, not on the slipping high-risk deadlines.corporate lawyerAI labelling and transparency obligations should already be built into contracts and product descriptions.lawyerClients' AI Act classifications and the map of new deadlines should be updated.AI Act after the Digital Omnibus: what applies and what has been delayedcompliance specialistMust re-map the post-omnibus deadlines and obligations in force in the company's compliance plan.corporate lawyerMust update advisory and corporate checklists to reflect the amended regulation.lawyerMust classify clients' AI systems according to the prohibitions and obligations now in force.AI Act digital omnibus pushes high-risk rules back to December 2027compliance specialistCompliance timelines must be redrawn: high-risk deadlines have slipped, but transparency obligations remain.corporate lawyerClients need a map of which obligation takes effect when after the omnibus.EU AI Act: Digital Omnibus pushes high-risk deadlines to 2027 as Article 50 transparency rules applycompliance specialistDespite the delay, transparency obligations must already be met, and preparation of high-risk systems should continue.corporate lawyerContracts need updating to reflect the applicable deadlines and the allocation of liability.lawyerClient preparation should be based on the changes made by the Omnibus.EU Digital Omnibus changes AI Act deadlines and heads for triloguecompliance specialistCompliance plans must be redrawn around the changed deadlines, but obligations already in force must not slip.corporate lawyerThe risk classification of AI systems and the commitments in vendor contracts should be reviewed against the amended timing.lawyerClients should be given a deadline calendar that reflects member-state authority designations.
Article 50 labelling requirements take sharper shape
EU AI Act transparency and labelling rules take effectcompliance specialistCompanies need to map where they encounter chatbots and AI-generated content, and introduce a labelling and documentation process.corporate lawyerService and supplier contracts must specify who is responsible for labelling and for fine risk.lawyerLabelling obligations may also apply to clients' legal, marketing and service content, so it is worth clarifying in advance.citizenUsers can now expect a clear indication when they encounter machine- or AI-generated content.AI Act transparency and enforcement rules apply from 2 Augustcompliance specialistCompanies must assess which interfaces require chatbot and AI-content labelling, and document this.corporate lawyerSoftware bought from a US provider does not exempt a company from the AI Act, so supplier contracts must be reviewed.AI Act transparency rules apply to Hungarian businesses from Augustcorporate lawyerFor Hungarian clients, it needs to be clarified which AI content and chatbots fall under the labelling obligation.compliance specialistMap where the company uses AI and set out the labelling practice in an internal policy.Anthropic watermarks Claude's text and file outputs to comply with EU rulescompliance specialistProvider-side watermarking shows how the machine-readable marking requirement is being met, and it is the point to raise in your own supplier assessments.lawyerText produced with Claude carries a watermark, so provenance checks on documents meant for clients need to take this into account.Hungarian trade outlets explain AI content labelling rules: deepfakes, chatbots, Article 50compliance specialistA labelling process for AI-generated text, images and video must be introduced in domestic communications too.corporate lawyerFor customer-service chatbots, users must be made aware that they are talking to a machine.AI Act Article 50: chatbots must be labelled, but most Dutch companies do not do itcompliance specialistFor customer service chatbots, the placement and language of the AI label must be checked, because practice falls short of the requirement.corporate lawyerContracts with chatbot providers should build in fulfilment of the transparency obligation.Hungarian media lawyer: not all AI-made content must be labelled, but errors risk billion-forint finescompliance specialistPublishing and marketing workflows need to identify which AI content falls under the labelling obligation.corporate lawyerContent-creation contracts should set out the liability and labelling rules for AI use.OpenAI introduces text watermarking in the EU to comply with AI Actcompliance specialistBecause of the obligation to make AI-generated text identifiable, must also check their own provider chain.corporate lawyerContracts with AI providers should address watermarking and labelling.AI Act transparency rules: labelling AI content and deepfakescompliance specialistChatbots and generated content must be labelled under Art. 50, and the process must be put in place.corporate lawyerFor clients, it must be assessed which AI outputs fall under the labelling obligation.AI Act: what applies, what was delayed, and the Article 50 transparency obligationscompliance specialistTransparency and AI literacy obligations must already be met; for high-risk systems, the new deadline is the basis for planning.corporate lawyerContracts should address both the changed deadline and the allocation of liability under Article 50.lawyerClients should also be advised to check that legal search tools and eDiscovery solutions comply.
The AI Office is already requesting information
EU Commission can now inspect AI models, restrict market access and fine providers under AI Actcompliance specialistModel providers' documentation and training-data disclosure obligations must be checked at the suppliers a company uses.corporate lawyerContracts with model suppliers should set out the consequences of a provider's failure to comply.lawyerA new field of regulatory proceedings opens up for representing providers.EU opens three channels for reporting AI Act breachescompliance specialistPrepare for competitors or affected parties to file reports, which means an internal escalation procedure is needed.citizenAnyone who spots a violation can choose from three official channels.AI Act enforcement and transparency obligations apply from 2 August 2026compliance specialistLabelling and transparency obligations for AI systems must be assessed and documented immediately.corporate lawyerAn inventory of the AI tools used by the company and a allocation of responsibilities must be drawn up.citizenComplaint routes are now available for reporting breaches of the AI Act.AI Act enforcement begins as the AI Office starts requesting information from companiescompliance specialistDocumentation should be kept ready for AI Office requests, as penalties can reach up to 7 percent of global turnover.corporate lawyerGPAI providers and deployers should set out their AI Act documentation obligations in contracts.European Commission enforces AI Act: GPAI obligations binding, transparency rules in effectcompliance specialistOrganisations should review which provisions apply to them based on their roles, product scope and territorial link.corporate lawyerContractual obligations of US and other third-country companies need to be aligned with the EU's scope of application.lawyerGiven the AI Act's penalty regime, compliance due diligence for clients is timely.GPAI Code of Practice transparency chapter published as Commission readies guidelinescompliance specialistGPAI providers must build the Code's documentation measures and the guidelines into their compliance process.corporate lawyerSigning the Code carries contractual and liability implications.European Commission asks more than 30 AI companies for safety and compliance informationcompliance specialistShould keep transparency and safety documentation ready, following the pattern of the inquiries to GPAI providers.corporate lawyerClients developing AI models must prepare for information requests from the Commission.EU starts enforcing AI Act, sends information requests to OpenAI and Anthropiccompliance specialistIncident-handling and reporting processes for AI agents must be documented ahead of AI Act supervisory questions.corporate lawyerFor clients that supply or use agents, the first steps of EU enforcement signal contractual risk.Big Tech presses EU to rework AI Act as enforcement lagscompliance specialistWith national supervisory authorities missing, the timing and substance of enforcement are uncertain.AI Act obligations for general-purpose AI models: biological risk and incident reportingcompliance specialistGPAI model providers must build risk management and incident reporting processes.lawyerFor providers of large models, the relevant voluntary code of practice can serve as a basis for compliance.First AI Act enforcement step: EU authority requests information from a providercompliance specialistA documented process for responding to information requests should be maintained.corporate lawyerAn internal protocol is needed for handling regulatory enquiries.
Standards and compliance presumption
Europe approves first AI Act standard, but compliance benefit is yet to arrivecompliance specialistUntil then, compliance documentation built on the standard should keep an independent method of demonstrating conformity.corporate lawyerContractual use of presumptions that refer to the standard should be planned only once the legal effect is clarified.EN 18286:2026, first European standard supporting AI Act implementation, publishedcompliance specialistCompliance teams should support the conformity of their systems with documentation based on harmonised standards.First harmonised standard for the AI Act published, giving presumption of conformitycompliance specialistFollowing the standard can give a presumption of conformity, so internal controls should be aligned with it.corporate lawyerThe standard may become a new basis for clients' compliance plans.First harmonised standard supporting the AI Act published in the Official Journalcompliance specialistCompliance documentation can be built on the standard.corporate lawyerThe standard can serve as a basis for contractual compliance requirements.EN 18286 becomes the first harmonised standard under the EU AI Actcompliance specialistThe standard should be built into conformity documentation and the quality management system.corporate lawyerReference to the standard can also be included as a contractual requirement.
The Hungarian AI regulatory framework takes shape
Hungary's AI authority launches labelling guidance site as firms found unpreparedcompliance specialistThe office's site can serve as a starting point for drafting an internal labelling and compliance policy.corporate lawyerHungarian clients should assess their AI systems and published content against the new labelling requirements.lawyerGiven the office's role and the open questions (K-Blog), advisory work needs to clarify regulatory expectations client by client.Hungarian bodies in AI Act enforcement: market surveillance, AI Council, media regulator NMHHcompliance specialistYou need to know which Hungarian authority to notify or approach with questions about live chatbots and HR-related AI.corporate lawyerThe high-risk classification of HR systems should be assessed in light of Hungarian regulatory practice.Hungarian government legislative council to consider draft AI lawcorporate lawyerFollow the text of the draft, because the national implementing rules will shape clients' compliance obligations.compliance specialistChanges in the draft will affect domestic supervisory and reporting processes.Hungary to get new AI authority; AI fraud victims must turn to different agenciescitizenAI-enabled fraud must be reported to the police as a crime, while another authority is competent for biometric cases.lawyerClients must be directed to the appropriate authority depending on the type of AI fraud.compliance specialistThe split of domestic supervisory powers must be built into the compliance plan.Hungary moves AI market surveillance to the minister for science and technologycompliance specialistOfficial requests and notifications must be addressed to the new competent body.corporate lawyerClient guidance on national AI Act enforcement should be updated to reflect the change of competence.lawyerIn administrative proceedings, competence and the route of appeal should be checked.Hungary adopts AI act and government decree, with fines of up to HUF 5.7 billioncompliance specialistAssess which systems qualify as high-risk and adjust the compliance plan accordingly.corporate lawyerLegal risk arising from the fine levels must be managed in contracts and internal policies.lawyerClients must be informed about the new Hungarian authority structure and the penalty regime.Hungary sets up Deputy State Secretariat for Artificial Intelligencecompliance specialistDomestic market surveillance coordination under the AI Act provides a new point of contact for compliance matters.corporate lawyerInformation on AI regulatory plans and legal harmonisation is best sought from the Deputy State Secretariat.lawyerIdentifying the competent body becomes easier when advising clients on the domestic application of the AI Act.
Google search interest
Hungary
| Topic and search term | Weekly | Average |
|---|---|---|
| The AI Act is delayed but already bitingai act | 2.1 | |
| Omnibus: only high-risk items delayeddigital omnibus | 0.8 | |
| Article 50 labelling requirements take sharper shapeAI content labeling | 0 | |
| The AI Office is already requesting informationai office | 1.3 | |
| Standards and compliance presumptionAI standard | 0 | |
| The Hungarian AI regulatory framework takes shapeAI law | 3.8 |
World
| Topic and search term | Weekly | Average |
|---|---|---|
| The AI Act is delayed but already bitingeu ai act | 3 | |
| Omnibus: only high-risk items delayeddigital omnibus | 0.1 | |
| Article 50 labelling requirements take sharper shapeai transparency | 2.2 | |
| The AI Office is already requesting informationai office | 16.9 | |
| Standards and compliance presumptionharmonised standards ai | 0 | |
| The Hungarian AI regulatory framework takes shapeai market surveillance | 0.1 |
Google Trends relative search index over the period studied, weekly average. A narrative and its sub-threads appear in a single comparison: 100 is the group's most-searched day, and the figures can only be compared within the group. The search term was chosen by machine analysis; it measures how much the term is searched, not how widespread the narrative is.
Who is affected and how
- compliance specialist
- Role and risk classification, and quality assurance must be aligned with the first harmonized standard now, before high-risk rules take effect in December 2027.
- corporate lawyer
- For services built on GPAI models, documentation must be requested from the provider, as the AI Office's information requests originated at the top of the chain with large model providers.
- lawyer
- Deadlines for high-risk systems under Annex III have slipped, but transparency obligations under Article 50 and GPAI rules are already in force; this must be clearly distinguished in client communication.
Hungary
Rapid institution-building is underway in Hungary. The AI Act and government decree were adopted, with fines up to 5.7 billion forints for high-risk systems (2026-09-21-01). Market supervision moved to the Minister of Science and Technology (2026-08-31-12), and the Deputy State Secretariat for Artificial Intelligence was established (2026-09-28-10).
Hungary moves AI market surveillance to the minister for science and technologycompliance specialistOfficial requests and notifications must be addressed to the new competent body.corporate lawyerClient guidance on national AI Act enforcement should be updated to reflect the change of competence.lawyerIn administrative proceedings, competence and the route of appeal should be checked.Hungary adopts AI act and government decree, with fines of up to HUF 5.7 billioncompliance specialistAssess which systems qualify as high-risk and adjust the compliance plan accordingly.corporate lawyerLegal risk arising from the fine levels must be managed in contracts and internal policies.lawyerClients must be informed about the new Hungarian authority structure and the penalty regime.Hungary sets up Deputy State Secretariat for Artificial Intelligencecompliance specialistDomestic market surveillance coordination under the AI Act provides a new point of contact for compliance matters.corporate lawyerInformation on AI regulatory plans and legal harmonisation is best sought from the Deputy State Secretariat.lawyerIdentifying the competent body becomes easier when advising clients on the domestic application of the AI Act.
Weekly trend
Turning points
Digital Omnibus becomes law, delaying high-risk AI deadlinesThe Omnibus entered into force, with high-risk obligations delayed to December 2027 and August 2028.AI Act enforcement begins as the AI Office starts requesting information from companiesThe AI Office has begun requesting information; the narrative has shifted from delay to enforcement.EU starts enforcing AI Act, sends information requests to OpenAI and AnthropicThe EU publicly discussed the start of enforcement, requesting information from OpenAI and Anthropic due to agent incidents.First harmonised standard supporting the AI Act published in the Official JournalThe first harmonized (quality management) standard supporting compliance with the AI Act was published in the EU Official Journal, providing a practical starting point for conformity.
Related narratives in the News magazine
Supporting stories
Digital Omnibus becomes law, delaying high-risk AI deadlinescompliance specialistThe preparation timeline must be adjusted, but the prohibitions and the rules for general-purpose models have not been postponed.corporate lawyerThe timing of obligations in contractual compliance commitments must be renegotiated in light of the amendment.lawyerClients should be told that the postponement does not cover every obligation.EU Commission can now inspect AI models, restrict market access and fine providers under AI Actcompliance specialistModel providers' documentation and training-data disclosure obligations must be checked at the suppliers a company uses.corporate lawyerContracts with model suppliers should set out the consequences of a provider's failure to comply.lawyerA new field of regulatory proceedings opens up for representing providers.EU digital omnibus in force: high-risk AI rules pushed back to December 2027corporate lawyerContract and compliance projects for high-risk AI systems must be rescheduled to the new deadlines.compliance specialistThe compliance roadmap must be updated, separating postponed obligations from those that are already live.lawyerAI Act advice to clients must be based on the new deadlines and the newly introduced prohibition.Digital Omnibus pushes AI Act high-risk deadlines to 2027–2028compliance specialistCompliance plans must be redrawn obligation by obligation, because only the deadline for high-risk systems has moved.corporate lawyerReferences to deadlines and provider commitments in contracts must be reviewed.lawyerClients must be told precisely which obligation has been postponed and which has not.AI Act enforcement and transparency obligations apply from 2 August 2026compliance specialistLabelling and transparency obligations for AI systems must be assessed and documented immediately.corporate lawyerAn inventory of the AI tools used by the company and a allocation of responsibilities must be drawn up.citizenComplaint routes are now available for reporting breaches of the AI Act.Europe approves first AI Act standard, but compliance benefit is yet to arrivecompliance specialistUntil then, compliance documentation built on the standard should keep an independent method of demonstrating conformity.corporate lawyerContractual use of presumptions that refer to the standard should be planned only once the legal effect is clarified.EU AI Act: Digital Omnibus delays high-risk deadline, but obligations remain in forcecompliance specialistDespite the delay, obligations already in force (such as transparency) must be met on time, and preparation for high-risk systems must continue.corporate lawyerThe roles under the AI Act (provider, deployer) and the Annex III classification need to be reviewed, including for contracts.lawyerClients need to be told what has been postponed and what remains in force.AI Omnibus shifts AI Act deadlines; critics say core problems remaincompliance specialistCompliance timelines must be aligned with the new deadlines, and sector-specific deviations tracked separately.corporate lawyerThe omnibus introduces no separate penalty, so sanction risk should be estimated under the original provisions of the AI Act.AI Act enforcement begins as the AI Office starts requesting information from companiescompliance specialistDocumentation should be kept ready for AI Office requests, as penalties can reach up to 7 percent of global turnover.corporate lawyerGPAI providers and deployers should set out their AI Act documentation obligations in contracts.Hungary moves AI market surveillance to the minister for science and technologycompliance specialistOfficial requests and notifications must be addressed to the new competent body.corporate lawyerClient guidance on national AI Act enforcement should be updated to reflect the change of competence.lawyerIn administrative proceedings, competence and the route of appeal should be checked.European Commission enforces AI Act: GPAI obligations binding, transparency rules in effectcompliance specialistOrganisations should review which provisions apply to them based on their roles, product scope and territorial link.corporate lawyerContractual obligations of US and other third-country companies need to be aligned with the EU's scope of application.lawyerGiven the AI Act's penalty regime, compliance due diligence for clients is timely.Digital Omnibus: EU to delay application of AI Act high-risk rulescompliance specialistCompliance roadmaps for high-risk systems must be re-planned around the amended deadlines, building in the uncertainty.corporate lawyerDelivery deadlines in AI procurement and supplier contracts should be aligned with the amended regulatory timetable.lawyerClients should be told that the delay is still part of a legislative process and is not final.Hungary adopts AI act and government decree, with fines of up to HUF 5.7 billioncompliance specialistAssess which systems qualify as high-risk and adjust the compliance plan accordingly.corporate lawyerLegal risk arising from the fine levels must be managed in contracts and internal policies.lawyerClients must be informed about the new Hungarian authority structure and the penalty regime.EU AI Act after the omnibus: high-risk rules slip, transparency obligations do notcompliance specialistThe focus now should be on Article 50 labelling and GPAI obligations, not on the slipping high-risk deadlines.corporate lawyerAI labelling and transparency obligations should already be built into contracts and product descriptions.lawyerClients' AI Act classifications and the map of new deadlines should be updated.Hungary sets up Deputy State Secretariat for Artificial Intelligencecompliance specialistDomestic market surveillance coordination under the AI Act provides a new point of contact for compliance matters.corporate lawyerInformation on AI regulatory plans and legal harmonisation is best sought from the Deputy State Secretariat.lawyerIdentifying the competent body becomes easier when advising clients on the domestic application of the AI Act.AI Act after the Digital Omnibus: what applies and what has been delayedcompliance specialistMust re-map the post-omnibus deadlines and obligations in force in the company's compliance plan.corporate lawyerMust update advisory and corporate checklists to reflect the amended regulation.lawyerMust classify clients' AI systems according to the prohibitions and obligations now in force.European Commission asks more than 30 AI companies for safety and compliance informationcompliance specialistShould keep transparency and safety documentation ready, following the pattern of the inquiries to GPAI providers.corporate lawyerClients developing AI models must prepare for information requests from the Commission.AI Act digital omnibus pushes high-risk rules back to December 2027compliance specialistCompliance timelines must be redrawn: high-risk deadlines have slipped, but transparency obligations remain.corporate lawyerClients need a map of which obligation takes effect when after the omnibus.EU starts enforcing AI Act, sends information requests to OpenAI and Anthropiccompliance specialistIncident-handling and reporting processes for AI agents must be documented ahead of AI Act supervisory questions.corporate lawyerFor clients that supply or use agents, the first steps of EU enforcement signal contractual risk.Big Tech presses EU to rework AI Act as enforcement lagscompliance specialistWith national supervisory authorities missing, the timing and substance of enforcement are uncertain.First harmonised standard supporting the AI Act published in the Official Journalcompliance specialistCompliance documentation can be built on the standard.corporate lawyerThe standard can serve as a basis for contractual compliance requirements.EU AI Act: Digital Omnibus pushes high-risk deadlines to 2027 as Article 50 transparency rules applycompliance specialistDespite the delay, transparency obligations must already be met, and preparation of high-risk systems should continue.corporate lawyerContracts need updating to reflect the applicable deadlines and the allocation of liability.lawyerClient preparation should be based on the changes made by the Omnibus.First AI Act enforcement step: EU authority requests information from a providercompliance specialistA documented process for responding to information requests should be maintained.corporate lawyerAn internal protocol is needed for handling regulatory enquiries.EU Digital Omnibus changes AI Act deadlines and heads for triloguecompliance specialistCompliance plans must be redrawn around the changed deadlines, but obligations already in force must not slip.corporate lawyerThe risk classification of AI systems and the commitments in vendor contracts should be reviewed against the amended timing.lawyerClients should be given a deadline calendar that reflects member-state authority designations.
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