modulos shipped the cleanest breakdown of the omnibus deal i've seen. it's worth reading once, then closing the tab and shipping the engineering anyway.
the 16-month delay does one thing - it removes the panic. it does not remove the requirement.
what the buyers i talked to today actually want
none of them want their march audit refunded. they want to know if the work was wasted. it wasn't.
the annex iii log retention requirement (6 months minimum, immutable, traceable input-to-output) didn't move. the conformity assessment didn't move. the post-market monitoring obligation didn't move. only the date the regulator can fine you moved.
the procurement gap nobody is talking about
large eu enterprises do vendor reviews 12-18 months before contract signature. that means buyers signing 2027 contracts are asking for compliance evidence right now. if your sdk doesn't ship article 12 logs by q3 2026, you lose the rfp before the deadline ever hits.
the omnibus is permission for vendors to keep building, not a license for buyers to stop asking.
what i'm telling clients
- ship the logger this quarter - it's a 4-hour build with the bizsuite ai-audit kit
- file the conformity assessment paperwork in q3 - reviewers are less busy
- update the procurement-ready one-pager - eu buyers print it and read it
$997 buys the audit, the log schema, and the report. the calendar moved. the work didn't.