European artificial intelligence regulation is changing again.
At a time when many businesses are still trying to understand how to comply with the European Artificial Intelligence Act, the European Union has approved a new reform known as the AI Omnibus, the Digital Omnibus on AI, or, more informally, the “AI Omnibus Law”.
But is this a completely new law? Does it replace the Artificial Intelligence Act? Have all obligations due to apply in August 2026 been postponed?
The answer is no.
The AI Omnibus does not repeal or replace Regulation (EU) 2024/1689. Its purpose is to amend certain aspects of the AI Act, simplify its implementation, reduce some administrative burdens and adapt certain deadlines to the actual availability of technical standards, guidelines and conformity assessment mechanisms.
What Is Regulation (EU) 2024/1689 on Artificial Intelligence?
Regulation (EU) 2024/1689, commonly known as the Artificial Intelligence Act or AI Act, is the European regulation establishing a common legal framework for the development, placing on the market and use of artificial intelligence systems within the European Union.
It was adopted on 13 June 2024, published in the Official Journal of the European Union on 12 July 2024 and entered into force on 1 August 2024.
Its application was designed to take place gradually.
Among other matters, the AI Act:
- prohibits certain artificial intelligence practices;
- classifies certain systems as high-risk AI systems;
- establishes obligations for providers, deployers, importers and distributors;
- regulates certain general-purpose artificial intelligence models;
- imposes transparency requirements for certain AI systems and content;
- and introduces an obligation to ensure an adequate level of AI literacy.
Not all businesses have the same obligations. Their responsibilities depend, among other factors, on the system being used, its intended purpose, its level of risk and the role performed by the company.
What Is the Digital Omnibus on AI?
The Digital Omnibus on AI is a new European regulation that amends specific aspects of Regulation (EU) 2024/1689.
The European Commission presented its proposal on 19 November 2025 as part of the European regulatory simplification package known as Omnibus VII.
The legislative process subsequently included the following stages:
- the Council adopted its negotiating position on 13 March 2026;
- the European Parliament adopted its position on 26 March 2026;
- Parliament and the Council reached a political agreement on 7 May 2026;
- the European Parliament approved the final text on 16 June 2026;
- and the Council gave its final approval on 29 June 2026.
It is therefore not a Spanish law, nor does it replace the AI Act in its entirety.
It is a European regulation that partially amends the existing legal framework.
Its entry into force will take place after publication in the Official Journal of the European Union, under the terms established in the final text.
Main Differences Between the AI Act and the AI Omnibus
1. The AI Act Creates the General Framework; the Omnibus Amends It
Regulation (EU) 2024/1689 remains the principal legal instrument.
It defines what constitutes an AI system, establishes risk categories, allocates responsibilities among the different operators and regulates the applicable legal obligations.
The AI Omnibus does not create a completely new legal system.
Instead, it introduces targeted amendments designed to facilitate the practical implementation of the original Regulation.
A simple way to explain the relationship is:
The AI Act establishes the rules of the game. The AI Omnibus modifies some of those rules, procedures and deadlines.
2. Certain High-Risk AI Obligations Are Postponed
One of the most significant changes concerns the rules applicable to certain high-risk AI systems.
The reform establishes the following latest application dates:
- 2 December 2027 for certain high-risk systems listed in Annex III, including systems used in areas such as employment, education, critical infrastructure, migration, access to essential services and biometrics.
- 2 August 2028 for high-risk systems embedded in products governed by the European product safety legislation listed in Annex I, including certain machinery, medical devices and industrial systems.
The purpose is to prevent these obligations from becoming fully enforceable before the necessary harmonised standards, guidelines and implementation tools are available.
However, this change must be interpreted carefully:
the entire AI Act has not been postponed until 2027 or 2028.
3. The August 2026 Obligations Have Not Disappeared
The approval of the AI Omnibus does not mean that 2 August 2026 is no longer an important date.
The transparency obligations under Article 50 remain particularly relevant, including those concerning certain systems that interact directly with individuals, artificially generated or manipulated content, and certain uses of emotion recognition or biometric categorisation.
A company using chatbots, virtual assistants, AI-generated images, synthetic voices or manipulated content should therefore not interpret the postponement of certain high-risk obligations as a general suspension of its duties.
4. Certain Administrative Burdens Are Simplified
The AI Omnibus aims to reduce duplication and facilitate compliance.
Its objectives include:
- simplifying certain documentation requirements;
- improving coordination between assessments required under different European laws;
- avoiding duplicated assessments where an AI system is already subject to sector-specific legislation;
- facilitating compliance for small and medium-sized enterprises;
- and providing greater clarity regarding the obligations of the different operators.
Simplification does not mean the removal of responsibility.
Businesses will still need to know which tools they use, why they use them, what data they process, who supervises the results and what risks may arise for clients, employees or third parties.
5. Certain Support Measures for Businesses Are Expanded
The AI Act already included specific measures designed to support SMEs.
The reform expands some of those measures and facilitation mechanisms, including measures aimed at small mid-cap companies.
This may lead to more proportionate documentation, regulatory support, controlled testing environments and implementation measures better adapted to the size and resources of the organisation.
However, being an SME or self-employed professional does not create a general exemption from the AI Act.
6. A New Prohibition Concerning Non-Consensual Intimate Content Is Introduced
The agreed text adds an express prohibition relating to AI systems designed to generate non-consensual sexual or intimate material involving identifiable individuals, as well as child sexual abuse material.
This includes so-called AI “nudifier” systems or applications.
The reform therefore demonstrates that the AI Omnibus is not limited to postponing deadlines or simplifying obligations.
It also introduces new prohibitions intended to protect fundamental rights and human dignity.
7. Transitional Rules Are Introduced for Certain Generative AI Systems
The reform provides for transitional arrangements for certain generative AI systems placed on the market or put into service before 2 August 2026.
In particular, it establishes an adaptation period for certain technical obligations relating to the marking and detection of AI-generated content.
This should not be confused with the general obligation to inform individuals when they are interacting directly with certain artificial intelligence systems.
Does the AI Omnibus Benefit Businesses?
In some respects, yes.
It provides additional time for compliance with certain high-risk obligations, reduces some duplication and aims to facilitate adaptation for SMEs and medium-sized businesses.
However, it may also create a false sense of security.
A business may wrongly conclude:
“As Europe has postponed the AI Act, we do not have to do anything until 2027.”
That conclusion would be incorrect.
Prohibited practices, AI literacy requirements, obligations concerning general-purpose AI models and certain transparency requirements follow their own application timetable.
Other laws also continue to apply, including:
- the General Data Protection Regulation;
- consumer protection legislation;
- employment law;
- intellectual property law;
- trade secret rules;
- advertising law;
- and contractual obligations towards clients and suppliers.
What Should an SME or Self-Employed Professional Do Now?
The first step is not to prepare hundreds of documents.
The first step is to understand how artificial intelligence is actually being used within the business
Once this inventory has been prepared, the company can determine its legal role, the risk level of each use and the measures that must be adopted.
Conclusion
The Digital Omnibus on AI does not replace the European Artificial Intelligence Act.
It amends it.
It introduces new deadlines for certain high-risk systems, simplifies procedures, expands some support measures and adds new prohibitions.
However, it does not suspend the general application of the AI Act or remove the obligations that are already applicable or due to apply in August 2026.
The practical conclusion is clear:
businesses have more time in relation to certain high-risk systems, but they should not postpone their general preparation for compliance with European artificial intelligence legislation.
At Bennet & Rey, we help SMEs, self-employed professionals and companies identify their AI tools, classify their uses, assess their risks and prepare the documentation required to comply with European legislation in a proportionate and understandable way.
The aim is not to stop using artificial intelligence.
The aim is to use it with knowledge, human oversight and legal certainty.
