Agreement in May, law in July

The Record, written in October 2026. A retrospective. This piece covers May 2026, when the co-legislators reached political agreement on the AI Omnibus, and was written afterwards from the documents. Nothing here was published at the time.

On 7 May 2026, the Council and the European Parliament reached political agreement on the AI element of the Digital Omnibus. The press coverage that followed was, almost uniformly, a story about a delay being confirmed: high-risk rules postponed, business relieved, deadline moved.

Three months later, on 24 July 2026, the text was published in the Official Journal as Regulation (EU) 2026/1744. It entered into force on 27 July.

Between those two dates — 7 May and 27 July — the regulation that would actually apply was not yet law. It was an agreement, a press release, and a set of drafts. And in that window, a large number of organisations made decisions on the strength of the headline.

What "political agreement" does not mean

It means the negotiators have settled the substance. It does not mean the text is final, the numbering is stable, or the lawyers have finished. Trilogue agreements go through legal-linguistic revision in every official language, and in that process articles move, definitions tighten, and the odd drafting error is fixed.

For an association, the practical consequence was this: if you read the agreement and started rewriting your supplier contracts against a clause number, you may have been right about the policy and wrong about the paragraph.

The dates that came out the other side

The final position, in the text that took effect on 27 July 2026:

• 2 December 2027 — the obligations for stand-alone high-risk systems listed in Annex III, which had been due on 2 August 2026.
• 2 August 2028 — Annex I systems, where AI is a safety component of a regulated product.

Crucially, those dates no longer depend on the harmonised standards being available. The conditional link was severed. In exchange for fifteen months, the sector gave up the argument that the rules wait for the paperwork.

The fifteen months, honestly

It is easy to be cynical about this and equally easy to be credulous, so it is worth being precise about what a deferral of this kind does.

It does not remove an obligation. It moves it, and it moves it to a date that is now unconditional. An association that treats December 2027 as a reprieve will arrive at December 2027 having done nothing for eighteen months, which is precisely the shape of the mistake described in the first piece in this series.

What it does do is change the order of work. With the high-risk obligations moved out, the parts of the Act that were already live — the prohibitions since February 2025, the literacy duty, the model obligations since August 2025 — became proportionally the whole of the association's legal exposure for the next year and a half. That is an unusually clean situation: a short list of things that already apply, and a clear deadline for the longer list.

What should have happened between May and July

One thing, and it is not legal work.

Somebody in each association should have written down, in a page, which systems they use that make judgements about people, who owns each one, and what the association would have to do differently by December 2027. That page is the input to every decision that follows: budget, procurement, the conversation with the board.

It costs a morning. It requires no consultant, no standard and no final text. And it would have been the only piece of work in that period that remained correct regardless of what the Official Journal said on 24 July.

Most organisations waited for the law. The ones that did not were finished, on this subject, before the law arrived.

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The Record · ← The Omnibus nobody asked for · Six days before the deadline →

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Running an association? The AI Act for associations — what your body must actually do sets out the whole thing on one page: whether you are a provider or a deployer, the four duties that reach a membership body, the dates that matter, and the five items of evidence a board will ask for.