The EU AI Act Readiness Planner (post-Omnibus)
Checklist
Map each of your AI systems against the EU AI Act dates as amended by the 2026 Digital Omnibus, and decide what to start now rather than in 2027.
Inventory and role
- List every AI system used, built or sold in the EU, including features built on third-party models.
- Record whether you act as provider, deployer, importer or distributor for each one.
- Note systems you have self-assessed as not high-risk: they still need registration.
Classification
- Check each system against the prohibited practices, including the new Omnibus prohibitions on non-consensual intimate imagery and CSAM generation.
- Check for Annex III stand-alone high-risk uses such as recruitment, credit, education and access to essential services.
- Check for AI embedded in Annex I regulated products such as medical devices.
- Check for Article 50 transparency triggers: chatbots, generative output, deepfakes.
Dates that apply
- Article 50 transparency: in force since 2 August 2026.
- Article 50(2) marking for systems placed on the market before 2 August 2026: 2 December 2026.
- Stand-alone Annex III high-risk obligations: 2 December 2027.
- Annex I embedded high-risk obligations: 2 August 2028.
Work to start now
- Logging and record-keeping designed into the system, not added later.
- Human oversight design: who can override, and how that is recorded.
- Data governance records for training and evaluation data.
- A written necessity case before processing special category data for bias detection.
Start a conversation
Have a product or AI decision to make?
Useful first calls usually start with one unclear decision, a deadline and a team that needs a practical next move.
Tell us about it