AI Omnibus Bill: A Law Has Been Signed, but Has Not Yet Been Published in the Official Journal

GAIGI Team

— 4 min de lecture
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The Council adopted the Digital Omnibus Act on AI on June 29, 2026, and the final act is dated July 8, 2026. With less than a month to go before August 2, the Official Journal has yet to be published. The act enters into force on the third day following its publication.

The Essentials in 30 Seconds

  • Adoption: June 29, 2026.
  • Final Act: July 8, 2026.
  • Effective Date: the third day following publication.
  • Original AI Act: August 2, 2026.

What Happened

The text amends the AI Act, the Civil Aviation Regulations, and the Machinery Regulations. Signature finalizes its content, but publication remains the formal condition for its entry into force. Organizations should therefore neither announce an effective date that has already passed nor suspend preparations. This distinction applies to contracts, launches, and management memos.

Adoption by the Council and the signature establish the political and legal content of the act. They do not replace the formality of publication. Until publication occurs, the exact effective date cannot be calculated, even though the “third-day rule” provides a clear mechanism.

This sequence is important for teams communicating externally. An announcement may describe the status of the procedure and the deadlines set forth in the text. It must not state that the amendments have already taken effect. This distinction is particularly useful when contracts refer to the applicable law.

The proximity of August 2 does not diminish the importance of this distinction. The provisions of the AI Act that are to apply according to the original schedule must be tracked separately from the adjustments introduced by the Omnibus Act. A single timeline would conflate obligations of different natures.

The Analysis

August 2, 2026 is fast approaching. The Omnibus Act primarily postpones the high-risk deadline to December 2, 2027, for Annex III and to August 2, 2028, for Annex I. It does not postpone the entire AI Act. The best approach is a two-tiered roadmap: prepare the inventory, roles, and documentation now, then implement the revised deadlines upon publication. The tagging of certain synthetic content systems must be ready by December 2, 2026.

The proposed postponement for “high risk” does not constitute a general suspension of governance work. A system must still be described with sufficient precision to allow for its classification. This enables stakeholders to adapt their plans after publication, without having to start over based on incomplete information.

The useful roadmap distinguishes between three columns: what is already covered by the regulation, what depends on the signed act, and what must be confirmed upon publication. This format avoids treating an expected date as a definite one. It also facilitates the provision of information to executives.

The article on summary content illustrates this need. Technical preparation can continue, while legal communication remains contingent on the formal timeline. The product and legal teams must share the same version of the assumptions used.

Operational Impact

For each system, the decision must be linked to a specific purpose, an identifiable version, a legal role, the individuals likely to be affected, and the deployment context. An up-to-date inventory, controlled user instructions, and a clear assignment of responsibilities are the prerequisites for demonstrable compliance. Management must be able to distinguish between directly applicable obligations, deferred deadlines, and tasks that remain relevant in all cases. This discipline facilitates responses to regulatory authorities, contract management, and coordination with business teams.

An internal registry can list, for each system, its function, vendor, deployment environment, and the date of the last review. The goal is not to produce a theoretical document. The objective is to quickly identify the affected systems when a deadline is confirmed.

Program managers should document decisions that require the text to take effect. This includes changes to clauses, training sessions, or updates to instructions. The list highlights the actions to be triggered after publication and those that can proceed immediately.

When communicating with service providers, it is best to request versioned information. The provider’s ability to explain limitations, updates, and available documentation will be useful regardless of any postponement. It also reduces the risk of relying on general statements.

What to Do Now

  • Map — identify the system, version, purpose, and legal role.
  • Document — preserve the reasoning and evidence.
  • Plan — assign a responsible party, deadline, and review.
  • Monitor — reconcile contracts, instructions, and technical measures.

Prepare a status report dated July 8. It must mention the Council’s adoption of the text, its signing, and the fact that it has not been published in the Official Journal. This report will serve as the benchmark for decisions made in the interim.

Identify projects whose launch depends on a high-risk qualification. For each one, distinguish between what must be designed immediately and what will be aligned with the effective date of the text. This separation avoids costly delays without creating excessive legal obligations.

Schedule a review as soon as the text is published. The review must confirm the published text, the calculation of the effective date, and the deadlines that have actually changed. It must also correct any internal documents that may have used overly definitive wording.

Update a single timeline table as soon as a formal step occurs. Each manager will be able to see the relevant rule, the reference date, and the expected action. The table thus serves as a shared reference for the legal, product, and procurement teams.

Sources

  • European Parliament, Legislative Train Schedule: vote on June 16, 2026; adoption by the Council on June 29; signing of the act on July 8: europarl.europa.eu
  • European Parliament, press release on the adoption of simplification measures: europarl.europa.eu
  • AI Act Service Desk, Article 113 of Regulation (EU) 2024/1689 on dates of application: ai-act-service-desk.ec.europa.eu

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