AI Act: The IMCO and LIBE Committees Propose Dates for High-Risk Cases

GAIGI Team

— 4 min de lecture
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On March 18, 2026, the European Parliament’s Committees on the Internal Market and Civil Liberties adopted their joint position on the Digital Omnibus package regarding the AI Act, by a vote of 101 in favor, 9 against, and 8 abstentions. They support postponing certain requirements for high-risk systems and propose fixed dates, including December 2, 2027, for autonomous systems listed in Annex III. At this stage, this is the committees’ position, not an amendment to the regulation that has already been adopted. For planning purposes, however, the change is significant: a fixed date is managed differently than a trigger dependent on a Commission decision.

Updated September 10, 2026. Regulation (EU) 2026/1744 amending the AI Act was published in the Official Journal on July 24, 2026, and entered into force on July 27. The new deadlines for high-risk systems are now set for December 2, 2027 (Annex III) and August 2, 2028 (Annex I). Full details in our reference article.

The Essentials in 30 Seconds

  • On March 18, 2026, IMCO and LIBE adopted a joint position by 101 votes in favor, 9 against, and 8 abstentions.
  • The committees support postponing the implementation of certain rules applicable to high-risk systems, currently scheduled for August 2, 2026.
  • They propose December 2, 2027 for high-risk systems specifically listed in the regulation, corresponding to the scope of Annex III.
  • They propose August 2, 2028 for systems covered by sector-specific safety and market surveillance legislation, or used as safety components.
  • The Parliament’s vote on the mandate in plenary is then expected on March 26, 2026.

What Has Happened

The debate centers on a simplification proposal presented by the Commission on November 19, 2025. The current regulation sets a general implementation date of August 2, 2026. For high-risk systems, this deadline has become a point of contention: the committees note that essential standards may not be finalized by that date. Their position therefore supports postponing the implementation of certain rules.

The vote result is clear: the Committee on the Internal Market and Consumer Protection (IMCO) and the Committee on Civil Liberties, Justice, and Home Affairs (LIBE) adopted their joint position by a vote of 101 in favor, 9 against, and 8 abstentions. This does not yet mark the conclusion of the legislative process. As of March 18, the Parliament’s website indicates that a plenary vote on the mandate is expected on March 26, 2026; negotiations with the Council cannot begin until this mandate has been approved.

From Conditional Trigger to Fixed Dates

The Commission’s initial proposal was based on a conditional mechanism. For high-risk systems under Article 6(2) and Annex III, the requirements of Chapter III would have taken effect six months after a Commission decision confirming the availability of adequate support measures. The text specifically cited harmonized standards, common specifications, and guidelines. A final deadline of December 2, 2027 remained proposed. For systems under Article 6(1) and Annex I, the mechanism provided for twelve months following the decision, with a final deadline of August 2, 2028.

The position adopted on March 18 favors a different planning signal. For systems specifically listed in the regulation, the Parliament proposes December 2, 2027. For systems covered by sector-specific safety and market surveillance legislation or used as safety components, the proposed date is August 2, 2028. The political choice is clear: the committees are seeking dates that provide predictability and legal certainty, rather than a start date that would depend on a subsequent assessment by the Commission.

The shift to a fixed date does not mean that standards, guidelines, or support measures lose their usefulness. It changes their function. Under a conditional regime, their availability served as a trigger. In the commissions’ scenario, they become primarily compliance tools to be deployed within a known timeline. This difference is critical for investment decisions and for commitments made with suppliers.

What a Fixed Date Means for Planning

A conditional date creates a governance challenge: the system must be prepared even though the exact start of the countdown is unknown. A fixed date makes the timeline measurable. Management can backward-plan the steps: system qualification, selection of controls, preparation of documentation, testing, training, governance review, contract updates, and the decision to launch the product. It can also allocate a budget and periodically check the gap between progress and the target date.

However, the increased visibility must not become an excuse to halt the work. First, the committees’ positions are still awaiting the plenary session scheduled for March 26. Second, the unamended regulation remains the legal framework. Third, the company must distinguish between the two scopes: the standalone systems in Annex III do not follow the same timeline as systems associated with products subject to sector-specific legislation. A single roadmap that does not account for these categories results in imprecise deadlines.

What to Watch for in Portfolios

The second issue is dependence on sector-specific regulations. Systems covered by EU legislation on safety and market surveillance, as well as safety components, require early coordination with product and quality teams. The proposed deadline of August 2, 2028 may seem far off, but testing, documentation, and contracting processes often take longer in these environments.

Finally, management must avoid limiting the discussion to the postponement. Obligations that are already in effect—particularly those related to general-purpose models—remain in place. The right approach is to secure the present and prepare for future scenarios without confusing a parliamentary position with definitively amended law.

What to Do Now

  • Maintain the legal timeline — do not replace the currently applicable deadline with a merely proposed date.
  • Develop a fixed timeline — assess the impact of a December 2, 2027, milestone for Annex III systems.
  • Separate the portfolios — isolate standalone systems from those integrated into safety products or components.
  • Work backward — establish the steps for qualification, documentation, inspections, and contracts based on each scenario.
  • Follow the procedure — update the roadmap after the plenary vote scheduled for March 26.

Sources

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