EU Digital Omnibus Reaches Political Agreement: High-Risk AI Duties Postponed to Late 2027

In May 2026, EU lawmakers reached political agreement on the package of regulatory adjustments known as the Digital Omnibus, revising the AI Act's implementation timeline: core obligations for standalone high-risk AI systems (Annex III) move from August 2026 to December 2, 2027, and obligations for high-risk AI embedded in regulated products (Annex I, such as medical devices) move to August 2, 2028.

It is important to understand what did not change: the AI literacy duty (Article 4) has applied since February 2025 and stands; general-purpose AI model obligations have applied since August 2025 and stand; and the closely watched Article 50 transparency obligations—informing users they are interacting with an AI system, and marking AI-generated content in machine-readable form—still take effect on August 2, 2026 as originally scheduled. What is postponed is the full high-risk compliance regime: risk management, technical documentation, logging, human oversight, conformity assessment, and registration.

Two clarifications matter for the language industry. First, machine translation itself is not a high-risk AI category—using AI to translate websites, marketing materials, software interfaces, or internal documentation does not trigger high-risk obligations; translation only inherits such requirements when embedded in a high-risk system, such as a medical device's multilingual interface. Second, the transparency duties concern translation buyers directly: enterprises using AI to generate multilingual content need internal processes for content marking and disclosure.

We advise clients to use the adjusted timeline for two tasks: inventory and classify internal AI tools, and build documented human oversight into translation workflows—certified processes such as ISO 18587 (post-editing) and ISO 27001 (information security) are the most pragmatic way to demonstrate diligent supervision.