may 7 2026 - the eu council and parliament agreed to move high-risk obligations under annex iii from aug 2 2026 to dec 2 2027. annex i (ai embedded in regulated products) moves to aug 2 2028.
every buyer i talked to today asked the same question - do i still need to act now.
the answer is yes, and the reason isn't legal, it's operational.
what the omnibus actually delayed
- the deadline to be compliant
- the fines if you're not
what the omnibus did not delay
- article 12 logs (immutable, 6mo retention, traceable to a specific input/output)
- the conformity assessment paperwork
- the post-market monitoring plan
- the procurement teams that already ask for ai act readiness in vendor questionnaires
why the engineering still ships this quarter
german + french procurement teams started asking for ai act readiness 9 months ago. that didn't move. the buyer's calendar is slower than brussels' calendar.
if you sell into the eu in 2027, your buyer asks for compliance evidence in 2026 - because by the time the deadline hits, every vendor is scrambling and the careful buyers want their procurement done by then.
what to ship now
- an article 12 logger (jsonl, hash-chained, signed)
- a conformity assessment template filled in for your specific high-risk system
- a procurement-friendly readiness report
bizsuite ships all three. $997, 4 hours, eu-defensible.
the calendar moved 16 months. the procurement timeline didn't.