EU Digital Omnibus Proposes to Simplify AI Act Implementation Timeline, November 2025

On 19 November 2025, the European Commission adopted the Digital Omnibus legislative package, which includes proposed amendments to Regulation (EU) 2024/1689 (the AI Act). The legislative proposal is at the European Parliament and Council negotiation stage. The Commission adopted the package to simplify the AI Act's implementation and preserve its innovation-friendly character while maintaining its risk-based architecture.

The AI Act entered into force on 1 August 2024 under Regulation (EU) 2024/1689, with the bulk of its obligations applying two years later on 2 August 2026. Within the existing AI Act structure, prohibited AI practices and AI literacy obligations applied from 2 February 2025, governance and GPAI model rules applied from 2 August 2025, and high-risk AI rules embedded in regulated products carry an extended transition period until 2 August 2027. The Digital Omnibus proposal, adopted by the Commission under its right of legislative initiative, proposes to adjust the timeline for the application of high-risk AI rules to a maximum of 16 months from the date when relevant harmonised standards become available, rather than applying them on a fixed date.

Beyond the timeline adjustment, the Digital Omnibus proposes five categories of targeted amendments: reinforcing the AI Office's powers and centralising oversight of AI systems built on GPAI models; extending simplified technical documentation requirements currently available to SMEs and startups (SMCs) to a broader class of operators; requiring the Commission and Member States to promote AI literacy while maintaining training obligations for high-risk AI deployers; broadening access to regulatory sandboxes from 2028 and extending real-world testing provisions; and adjusting the AI Act's procedures to clarify its interplay with sector-specific laws. AI providers, deployers, and importers operating GPAI models or high-risk AI systems in the EU should monitor the co-legislative process between the European Parliament and the Council, as the Omnibus amendments, if adopted, will modify their compliance timelines and documentation obligations.

The Digital Omnibus proposal does not alter the existing compliance obligations that are already in force under the AI Act. Prohibited practices banned from 2 February 2025 and GPAI model obligations that applied from 2 August 2025 remain in effect. The Omnibus has not yet been formally adopted by the co-legislators; until the European Parliament and Council reach a political agreement and the final text is published in the Official Journal, the current AI Act deadlines continue to apply.

Source: European Commission, "AI Act" page, digital-strategy.ec.europa.eu, updated 27 January 2026, available at: https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai (confirming Digital Omnibus adoption on 19 November 2025 and application timelines); Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act), OJ L, 2024/1689, 12 July 2024. Verified 10 March 2026.

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.