The Digital Omnibus, explained for media companies
The Digital Omnibus delayed the EU AI Act’s high-risk deadlines but left the transparency rules that reach media companies untouched. What actually changed.
If you have seen the line that the EU delayed its AI Act and wondered whether the transparency duty on your last production had just evaporated, the short answer is no. The Digital Omnibus, a simplification package that entered into force on 27 July 2026 (opens in a new tab) after publication in the Official Journal on 24 July, did push several AI Act deadlines back, but the ones it moved are the high-risk deadlines, and the transparency rules that actually reach a media company were left exactly where they were. The delay was real. It was just not your delay.
What the Omnibus is
The Digital Omnibus is the Commission’s tidying-up of the AI Act, a set of amendments meant to reduce overlap with other laws, simplify some obligations, and give industry more time on the hardest parts of the regime. It is now law rather than a proposal, which is worth saying because much of the commentary written earlier in 2026 described it while it was still being negotiated, and a package that is agreed but not yet in force is a different thing from one that has amended the statute. As of its entry into force at the end of July 2026, it has.
What it delayed
The substance of the delay concerns high-risk AI systems, the tier that covers AI making or heavily informing consequential decisions about people. The obligations for standalone high-risk systems moved to 2 December 2027, and those for high-risk systems embedded in regulated products, the medical devices and machinery that carry their own EU safety rules, moved to 2 August 2028. These are meaningful extensions, and they are the reason you saw the word delay in the headlines, but they matter to a production only in the uncommon case where it deploys a genuinely high-risk system, such as an AI tool used to screen or score the people it hires. For the AI a production ordinarily uses, the generative tools in development, post and marketing, none of this is the operative timeline.
What it did not delay
The Article 50 transparency obligations were not deferred and apply from 2 August 2026 (opens in a new tab), which is the piece that reaches a media company. The duty to tell audiences when they are seeing AI-generated or manipulated content, and above all a deepfake, is live now, and the what-changed-on-2-August guide covers how it works. The only timing concession in this area is a narrow transitional one that the Omnibus kept in place: generative AI systems that were already on the market before 2 August 2026 have until 2 December 2026 to meet the machine-readable marking requirement. That is a grace period for a technical marking obligation, not a reprieve from the disclosure duty itself.
The couple of other changes worth a glance
Two further items are worth knowing even though they sit outside the transparency rules. The Omnibus added new prohibitions, banning AI systems that generate child sexual abuse material or non-consensual intimate imagery, and these apply from 2 December 2026; they are not a production compliance task so much as a hard line the law now draws. It also simplified the AI literacy duty, the expectation that the people using these tools understand them, without removing it, so the literacy obligation that has applied since February 2025 remains, in a lighter form. None of this changes the shape of what a producer has to do, and that is rather the point of a simplification package.
What it means for you
The useful takeaway is a calm one. The reporting about a delayed AI Act is accurate as far as it goes, but the delay lands on a tier of the Act that most productions never touch, and the duty that does touch you was deliberately left running on its original clock. So the practical work is unchanged from what it was in the summer: know which AI tools were used on a production and where their outputs ended up, decide what needs a disclosure, and disclose it. If you want the wider frame, our plain-language guide to the Act for producers sets the Omnibus in context, and the Article 50 guide is the one to read if the disclosure duty is what you are actually working on.