Dear Colleagues,

On Monday, the Council of the EU adopted the AI Omnibus without debate, as an A-item, during the Employment and Social Affairs Council meeting. [Confirmed: June 29, 2026, Agence Europe] The vote is the final legislative step before publication, closing out a process that began with the May 7 political deal and cleared the European Parliament on June 16 by 423 votes to 57.

The substance is now settled pending publication. Compliance for standalone Annex III high-risk systems moves from August 2, 2026 to December 2, 2027. High-risk AI embedded in regulated products under Annex I — medical devices, machinery, toys — gets until August 2, 2028. Watermarking duties under Article 50 and a new prohibited-practice ban on non-consensual “nudification” tools under Article 5 both land on December 2, 2026.

The nudification provision, added after the backlash over Grok-generated imagery, reaches both providers who place such systems on the EU market and deployers who use general-purpose generative tools for that purpose. Providers of image, video, and audio models should treat output-stage filtering as a December 2026 deliverable, not a 2027 one.

Here is the catch compliance teams keep missing: the regulation only enters into force three days after Official Journal publication, which the Council says should happen “shortly.” Until that publication date lands, the original August 2, 2026 high-risk deadline remains the operative legal baseline. Annex III teams should keep building, not stand down, until the OJ date is confirmed in writing.

The timing lines up with a presidency handover. Ireland took over the Council presidency from Cyprus today, July 1, and its published programme names finalizing this file — plus the wider Digital Omnibus — as an early priority. Ireland has also confirmed an AI Summit in Dublin on October 14, convening EU and global leaders on AI-driven competitiveness.

Watch the Official Journal over the coming days. Publication starts the three-day countdown that makes December 2, 2027 and December 2, 2028 real, enforceable dates rather than political commitments.

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