The regulatory wave

The regulatory wave A lifecycle diagram generated by Archify. 01 / Dated stages 02 / Legacy systems 03 / What the dates demand Digital Omnibus · in force · Dated stages · 27 July 2026 01 Digital Omnibus in force 27 July 2026 GPAI · enforcement live · Dated stages · 2 August 2026 02 GPAI enforcement live 2 August 2026 New Art. 5 bans · + Art. 50(2) marking · Dated stages · 2 December 2026 03 New Art. 5 bans + Art. 50(2) marking 2 December 2026 Annex III · deferred high-risk · Dated stages · 2 December 2027 04 Annex III deferred high-risk 2 December 2027 Annex I · deferred, embedded · Dated stages · 2 August 2028 05 Annex I deferred, embedded 2 August 2028 Public authorities · legacy high-risk · Legacy systems · 2 August 2030 06 Public authorities legacy high-risk 2 August 2030 Stack before the dates · build in order now · What the dates demand · build order, ch. 04 07 Stack before the dates build in order now build order, ch. 04 build before Legend terminal success neutral

Two moves in one summer

  • • The Digital Omnibus entered into force on 27 July 2026 and reset the high-risk clock
  • • GPAI enforcement went live on 2 August 2026, with fines up to 3% of turnover or EUR 15 million
  • • The law began asking for engineered evidence

The next flips, dated in the Omnibus

  • • 2 December 2026: new Article 5 bans on AI-generated intimate imagery without consent and child sexual abuse material, and Article 50(2) marking for generative systems placed on the market before 2 August 2026
  • • Annex III high-risk obligations moved to 2 December 2027, Annex I embedded high-risk to 2 August 2028
  • • High-risk systems for public authorities already on the market must comply by 2 August 2030

Runway, not relief

  • • The extra time is more runway to do the engineering, not less of it
  • • Pick the next stage and map its obligations to artefacts in chapter 08
  • • Build the stack before the dates, not after them