EU Proposes AI Overhaul

As companies are preparing to comply with the EU AI Act, the European Commission is proposing to reopen its flagship AI regulation. The Commission is proposing a “Digital Omnibus” to reduce compliance burdens and streamline digital regulations, including the EU AI Act. One of the many changes proposed by the legislation is a delay in compliance timelines for high-risk AI systems. A recent Cooley memo discusses the omnibus proposal and writes of the timeline extension:

“Under the current EU AI Act, the rules on high-risk AI systems apply from 2 August 2026 (for Annex III use cases) or 2 August 2027 (for high-risk systems embedded into or comprising regulated products). The omnibus proposal seeks to delay the application date for these requirements, making application conditional on the readiness of applicable harmonised standards, common specifications or guidelines. A new long-stop date means that the rules on high-risk systems would apply, at the latest, from 2 December 2027 (Annex III systems) and 2 August 2028 (systems comprising or embedded into regulated products), even if standards are still lagging.”

The EU is currently conducting trilogues on its sustainability omnibus, and the digital omnibus appears to be next in line. The digital omnibus is still early in the legislative process. The EU Council and Parliament will need to adopt negotiating positions. After that, those positions will be debated among the Commission, Parliament, and Council until a final text is adopted. The EU government is likely targeting mid-2026 for implementation to avoid overlap with the existing August 2, 2026, deadline for high-risk AI regulations. However, negotiations could carry into 2027.