The Digital Omnibus did not delay chatbot disclosure
Updated June 11, 2026
There is a comfortable rumor going around that "the AI Act got delayed." It is half true, and the half that is true does not help chatbot owners. Here is what the May 7, 2026 omnibus agreement actually did.
What was delayed
The Council and Parliament reached a provisional agreement on the so-called Digital Omnibus on AI, the first set of amendments to the AI Act since it passed. It pushes back the high-risk rules: obligations for stand-alone high-risk systems now apply from December 2, 2027, and for high-risk systems embedded in products from August 2, 2028. If you are building medical triage AI or hiring-decision systems, you got breathing room.
What was not delayed
The transparency obligations in Article 50, including the duty to tell people they are interacting with an AI system, were left exactly where they were: applicable from August 2, 2026. The Council's own press release spells out the new high-risk dates and confirms the transparency timeline. Law firm client alerts since the agreement say the same thing in one voice: chatbot disclosure proceeds as scheduled.
The penalty regime did not move either. Fines for Article 50 breaches still run up to EUR 15 million or 3% of worldwide turnover, and the penalties chapter has been applicable since August 2025.
The one transparency change, and it cuts the other way
The omnibus touched transparency in exactly one place: Article 50(2), the duty to mark AI-generated content in machine-readable form. Systems already on the market before August 2, 2026 get a transitional period for that marking duty, until December 2, 2026. Notably, negotiators shortened that grace period from the proposed six months to three. If anything, the direction of travel was less leniency, not more.
So 2026 now has two transparency deadlines: August 2 for telling people they are talking to AI, and December 2 for marking AI-generated content from systems that predate August.
Why this matters for the "wait and see" plan
The rational case for waiting was "Brussels keeps moving the goalposts, this will slip too." That case just resolved against you. The legislators had their one big chance to delay Article 50 in the omnibus, with industry asking for exactly that, and they chose to keep the date. The agreement still needs a formal adoption vote, but even if that vote slipped, the original Act's August 2 date stands on its own. There is no remaining mechanism for this deadline to quietly disappear.
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Disclosed provides compliance tooling and records; this document is not legal advice. Review it with your counsel before relying on it.