10.3Timeline Note (as of July 2026)

The EU AI Act rolls out in phases. The banned "unacceptable-risk" practices and the general-purpose AI (GPAI) obligations already applied in 2025. The headline change for high-risk systems came in mid-2026: the Digital Omnibus package (provisional agreement May-June 2026, Council green light 29 June 2026) defers the Annex III high-risk obligations to 2 December 2027, and the Annex I (product-regulated) high-risk obligations to 2 August 2028.

Important caveat: until the Digital Omnibus is formally enacted, the original 2 August 2026 date for high-risk obligations technically remains binding. Do not treat the deferral as a reason to pause compliance work -- build the bias, transparency, human-oversight, and audit-trail testing now, because the requirements themselves are unchanged and the binding dates could still shift.