Table of contents
What Happened
Both EU co-legislators have now adopted their respective positions on the Digital Omnibus on AI:
Trilogue negotiations (formal talks between Parliament, Council and Commission) are expected to begin in April 2026, with a target agreement by May 2026. The Cypriot Council Presidency aims for ratification before August 2026.
Confirmed New Dates (both institutions’ positions)
| Obligation | Original date | Proposed new date |
|---|---|---|
| Annex III high-risk systems (standalone) | August 2, 2026 | December 2, 2027 |
| Annex I safety components (products) | August 2, 2027 | August 2, 2028 |
| Regulatory sandboxes | August 2, 2026 | December 2, 2027 |
Source: Council (March 13) and Parliament (March 26) positions. Dates subject to trilogue outcome.
The “Readiness Gate” Mechanism
Parliament introduces a conditional trigger: high-risk obligations only apply 6 months after a Commission decision confirming that compliance support (harmonised standards, guidance, tools) is available. 12 months for Annex I systems. The backstop dates (Dec 2027 / Aug 2028) apply if the Commission never issues that decision.
New Prohibited Practice: Nudifiers
Both institutions add a new prohibition to Art. 5: AI systems generating non-consensual intimate imagery (“nudifiers”) and child sexual abuse material. Both positions are aligned. This ban is expected to survive trilogue.
What Is NOT Paused
The following obligations remain fully in force. None of them are affected:
What IS Conditionally Paused
Both institutions’ positions target a specific subset of obligations:
Why “Paused” Is the Wrong Word
The headline narrative will be: “the AI Act is paused, we have time.” This is dangerous and inaccurate.
Art. 5, Art. 50, and GPAI obligations remain fully active. A conditional delay on Annex III does not eliminate regulatory exposure. It displaces it. The obligations that carry the most immediate penalty risk (prohibited practices at 35M€ or 7% of turnover) are untouched.
Organizations that interpret this vote as permission to wait are not reducing risk. They are building undocumented exposure during the exact period when early positioning carries the most weight.
Sources
- [1]EUR-Lex (July 12, 2024) · Regulation (EU) 2024/1689 — Artificial Intelligence Act (full text) eur-lex.europa.eu/eli
- [2]European Commission (February 26, 2025) · Digital Omnibus — Proposal to Simplify and Strengthen Digital Regulation digital-strategy.ec.europa.eu/en
- [3]European Parliament (March 18, 2025) · MEPs Support Postponement of Some AI Act Deadlines www.europarl.europa.eu/news
- [4]
- [5]EU AI Act · Article 6 — Classification Rules for High-Risk AI Systems artificialintelligenceact.eu/article
- [6]
- [7]
- [8]
- [9]European Parliament (March 18, 2026) · MEPs support postponement of certain rules on artificial intelligence www.europarl.europa.eu/news
- [10]Council of the EU (March 13, 2026) · Council agrees position to streamline rules on artificial intelligence www.consilium.europa.eu/en
- [11]European Parliament (March 26, 2026) · Plenary adoption of Digital Omnibus on AI negotiating position www.europarl.europa.eu/legislative-train
- [12]EDPB + EDPS (January 21, 2026) · Joint Opinion 1/2026 on Digital Omnibus on AI www.edpb.europa.eu/our-work-tools
- [13]
Six questions on your own uses, two minutes, no account. Your answers come back to you as a text you can take away — nothing is sent to us.
Take the checkSprinkling Act examines one workflow already running on AI: how you describe it, what the elements you provide establish, and the distance between the two. Before you extend, renew or change it.
Why Your Position Matters More Now, Not Less
A dated, article-mapped assessment produced before any enforcement date is evidence of proactive regulatory positioning. This principle is already established in adjacent regulatory markets (GDPR, NIS2, DORA) where early documentation consistently demonstrated good faith during enforcement.
The date on your report is your strongest argument. Whether enforcement happens in December 2027 or earlier, having a documented position predating enforcement demonstrates that your organization took the regulation seriously before it was required to.
What You Should Do Now
The smart move was the same whether or not the postponement was adopted (it was: Digital Omnibus adopted 29 June 2026):
Not sure where you stand? The free Sprinkling Act diagnostic maps your exposure article by article, including the obligations that are already in force.