Did the Digital Omnibus delay the AI disclosure rules?

Short answer

No — with one narrow exception. The postponements discussed around the Digital Omnibus package concern the high-risk provisions, not the transparency duties in Article 50. The same package did, however, insert a transition rule for Article 50(2): until 2 December 2026, for providers of AI systems placed on the market before 2 August 2026.

Why that is

This question is on the list because the information around it is contradictory: several publications report a delay without making clear which part of the regulation moved. We checked it against four independent sources, listed in our source documentation. The result in two sentences: the widely reported delay concerns the high-risk chapter. Article 50 itself was not postponed and has applied since 2 August 2026, paragraphs 1 through 4. That is where the simple answer ends, and without the rest it would be a half-truth: Regulation (EU) 2026/1744 inserted a transition rule into Article 111(4) that touches paragraph 2 only, addresses providers of AI systems only, and covers only systems placed on the market before 2 August 2026. For anything that does not meet all three at once, paragraph 2 has applied since 2 August 2026. Which of the two roles somebody falls into is not something we assert — it is not a question a website can be measured against. And as with every statement about ongoing legislation: we report the position our sources support and will update this page when it moves.

What this means in practice

If someone cites the Digital Omnibus to tell you to hold off on labeling, ask two things: which article they mean, and which of the three conditions of the transition rule they are relying on. If no answer comes back, the advice is worth nothing. For the chat disclosure under paragraph 1 the debate is moot anyway: the transition rule does not touch it, and it is one sentence in a greeting message — deferring it costs more effort than doing it.

Check it on your own page

What is on your page is independent of how the legislative process goes. The check measures the state today — what a reviewer would see if they looked now.

Related questions

• What has applied since 2 August 2026 — and for whom is 2 December 2026 a transition deadline?
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