What moved
- High-risk systems listed in Annex III, such as AI used in recruitment, credit scoring, education or biometrics: from 2 August 2026 to 2 December 2027.
- AI built into regulated products (Annex I): 2 August 2028.
What did not move
- Transparency, from 2 August 2026. People must be told when they are interacting with an AI system. That covers a WhatsApp bot or a website chat that answers customers.
- Marking AI-generated content. Providers of systems that generate audio, images, video or text and were on the market before 2 August 2026 have until 2 December 2026 to comply with the marking rule in Article 50(2).
- Staff AI literacy has been an obligation since 2 February 2025.
New: a “small mid-cap” category
The Omnibus extends several SME simplifications to companies that are not SMEs but have fewer than 750 employees and either turnover up to €150 million or a balance sheet up to €129 million. These include simplified technical documentation, more proportionate quality-management expectations, priority access to regulatory sandboxes and tailored penalty caps.
What it means for a team of 15 to 250
Most of what mid-size businesses use AI for, like drafting replies, reading invoices or building reports, is not high-risk. The rules that touch you today are the simple ones: tell customers when they are talking to AI, label generated content where required, and make sure the people using AI know what they are doing.
If you use AI to screen CVs or decide who gets credit, that is Annex III territory. December 2027 gives you time, not an exemption.
A checklist for this month
- Find every place AI talks to a customer and add a one-line disclosure.
- Keep a simple register: which AI tools you use, for what, and who owns each one.
- Make sure a person reviews anything that decides about people or money.
- Give the staff who use AI a short, practical training session.
This is a summary of secondary legal analysis, not legal advice. Check the official text on EUR-Lex for your own case.
Start the register today. Our free AI tool register is a ready-made sheet with the columns above: tool, purpose, owner, data, customer-facing, reviewer.
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