Money · Operator memo

Did the Digital Omnibus delay EU AI Act Article 50?

No. The AI Omnibus (Regulation (EU) 2026/1744) moved high-risk timelines. It did not move Article 50 transparency.

Chatbot notice, deepfake labels, and machine-readable marks have been enforceable since 2 August 2026. The Commission said so on 31 July 2026. If you have an in-product AI assistant and EU users, ship the first-interaction notice this week.

Get the $29 Article 50 Ship Checklist Buy the $149 Money Brief

Not legal advice. Related: Does Article 50 apply? · Exact notice words · 2 December marking

What the Omnibus actually moved

Political agreement on the AI Omnibus landed 7 May 2026. The text entered into force on 27 July 2026. The Commission’s AI Act page (last update 3 August 2026) is clear on the new high-risk calendar:

Stack What moved New date
Annex III high-risk use cases (biometrics, education, employment, migration, justice, etc.) Yes. Delayed by the Omnibus. 2 December 2027
High-risk systems inside regulated products (Annex I / product-safety stack) Yes. Delayed by the Omnibus. 2 August 2028
Article 50 transparency (chatbots, deepfakes, machine-readable marks) No. Not in the delay. 2 August 2026. Already live.

If your compliance thread is “Omnibus bought us a year,” that thread is about high-risk Annex III. It is not a pause on chatbot disclosure.

What the Commission said on 31 July

The Commission’s press release of 31 July 2026 states that from 2 August 2026 the AI Office and national authorities begin enforcing the AI Act, and that on the same date the new transparency rules start to apply.

Under those rules:

That is Article 50 in plain language. It is not Annex III. It is not the product-safety stack. It does not wait for 2027.

What to do this week

  1. Ship a first-interaction notice in the product if it is not already live. Commission example: “You are interacting with an AI system.”
  2. Check voice, email, and Slack surfaces, not just the web widget.
  3. Do not open a high-risk workstream because of this page. That calendar is December 2027 / August 2028.
  4. Inventory generative outputs. Open a 2 December 2026 marking ticket only if the system was already on the market before 2 August.

Need the exact line and a print-and-tick inventory? That is the $29 checklist. Need someone to kill the rumour against your specific product surfaces? That is the $149 Money Brief. The public sample is this exact question.

Buy the operator pack

The $29 Article 50 Ship Checklist is the inventory, notice line, deepfake labels, and 2 December ticket. The $149 Money Brief is the sourced memo if you think you are in the “obvious” exception, you trained a model, or a national authority has written.

Free notice-copy tool · Exact wording page

Sources

Fetched 28 August 2026 (PT). No invented quotes.

  1. European Commission, “Commission starts enforcing AI Act rules and new transparency requirements on 2 August,” press release, 31 July 2026. digital-strategy.ec.europa.eu
  2. European Commission, AI Act policy page, last update 3 August 2026 (Omnibus timeline: Annex III high-risk from 2 December 2027; Annex I product systems from 2 August 2028; Omnibus in force 27 July 2026). digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai
  3. European Commission, Article 50 FAQ, last update 24 July 2026. Transparency obligations under Article 50 of the AI Act
  4. European Commission, “Commission publishes guidelines on transparency obligations,” 20 July 2026. digital-strategy.ec.europa.eu