The Digital Omnibus on AI enters into force: the "high-risk" deadline slips to 2027, but saying "you're talking to an AI" stays mandatory on August 2, 2026
Published in the EU Official Journal on July 24 and entered into force on the 27th, the Digital Omnibus pushes the AI Act's Annex III deadline back to December 2027. What the media coverage of the delay leaves out: Article 50's transparency obligation — telling the user they're talking to an AI — hasn't moved at all, still due August 2, 2026.
The Digital Omnibus on AI, published in the European Union's Official Journal on July 24, 2026 and entered into force on July 27, is the first package of formal amendments to the AI Act since it was adopted in 2024. Its most-discussed change: the deadline for autonomous high-risk AI systems (Annex III — employment, education, critical infrastructure, law enforcement) slips by two years and four months, from August 2, 2026 to December 2, 2027; for AI embedded in products already covered by sector safety legislation (Annex I), the deadline runs to August 2, 2028. But one point goes almost unnoticed in the media coverage of the delay: Article 50, which requires informing users when they're interacting with an AI system (unless that's obvious from context), is NOT affected by this delay. Law firm Lewis Silkin spells it out in black and white in its July 27 analysis: "the remaining Article 50 transparency obligations [...] continue to apply from 2 August 2026." Six days away.
In practice, that targets any small business that put a chatbot or AI assistant on its site without clearly saying so from the very first interaction. This isn't a legal nuance: starting August 2, a visitor writing to an assistant that passes itself off as human — or that never states it's an AI — exposes the company running it. We checked our own case before writing this article, not after: Chichi, AppH's contact-intake assistant, displays "AppH virtual assistant" as a permanent subtitle as soon as the chat window opens, and explicitly introduces itself as such in its very first message, in all 4 languages of the site — not a line buried in a terms-of-use page nobody reads.
For AppH
- Chichi already complies with Article 50 without us having to change a single line of code for this deadline — the persistent subtitle and the opening message existed even before the Digital Omnibus was published, because AI transparency has always been part of our brand values, not just compliance.
- The Annex III delay changes nothing about AppManager's stance on human approval — our modules never waited for a legal obligation to require explicit validation before an agent acts, so this delay opens no window where AppH would become "less compliant" than before.
Against / what doesn't apply
- This check only covers Chichi — if an AppH client runs another conversational AI tool on their own site, outside of AppManager, it's on them to verify their own Article 50 compliance; AppH can't audit that on their behalf.
- "Telling the user they're talking to an AI" is just one obligation among several in the AI Act — it's not full compliance, and the Annex III delay doesn't excuse anyone from tracking how the text evolves if their activity ever falls within the scope of high-risk systems.
We could have waited until August 2 to check that Chichi complies with Article 50. We did it this week instead, rereading the source code line by line, not relying on a memory of how the widget was built months ago. The difference between "we think we're compliant" and "we checked" is exactly the kind of gap this deadline delay doesn't excuse. What strikes us about this delay isn't that it gives breathing room to large companies building high-risk systems — it's that it changes NOTHING for a small business that, like most of our clients, never intended to build a system that scores employees or candidates. The real question we ask any client turning on an AI chatbot on their site stays the same as ever, delay or not: does the person on the other end know they're talking to a machine, from the very first line? If the answer is no, that's not a compliance box to tick later — it's a lie by omission, and that stays true even without the AI Act.
Reviewed by a human at AppH