The Digital Omnibus on AI enters into force: the “high-risk” deadline slides to 2027, but saying “you're talking to an AI” is still mandatory from 2 August 2026
Published in the EU Official Journal on 24 July and in force since the 27th, the Digital Omnibus pushes the AI Act's Annex III deadline back to December 2027. What most of the coverage of that delay leaves out: the Article 50 transparency duty — telling users they're talking to an AI — hasn't moved. It's still 2 August 2026.
The Digital Omnibus on AI, published in the EU Official Journal on 24 July 2026 and in force since 27 July, is the first formal amendment package to the AI Act since it was adopted in 2024. Its most-covered change: the application deadline for stand-alone high-risk AI systems (Annex III — employment, education, critical infrastructure, law enforcement) slides by two years and four months, from 2 August 2026 to 2 December 2027; for AI embedded in products already covered by sectoral safety legislation (Annex I), the deadline runs to 2 August 2028. But one point barely shows up in the coverage of that delay: Article 50, which requires informing users they're interacting with an AI system (unless that's obvious from context), is NOT part of it. Law firm Lewis Silkin spells it out in its 27 July analysis: “the remaining transparency obligations under Article 50 [...] continue to apply from 2 August 2026.” Six days from now.
In practice, that covers any small business that's put a chatbot or AI assistant on its site without saying so clearly from the very first exchange. This isn't a legal nicety: from 2 August, a visitor typing to an assistant that passes itself off as human — or that never mentions it's an AI — leaves the business running it exposed. We checked our own case before writing this piece, not after: Chichi, AppH's own front-desk assistant, shows “AppH virtual assistant” as a persistent subtitle the moment the chat window opens, and introduces itself as such explicitly in its very first message, across all 4 site languages — not a line buried in a terms-of-service page nobody reads.
For AppH
- Chichi already meets Article 50 without a single line of code changed for this deadline — the persistent subtitle and opening message existed before the Digital Omnibus was even published, because being upfront about AI was always one of our brand values, not just a compliance checkbox.
- The Annex III delay changes nothing about AppManager's stance on human approval — our modules never waited for a legal requirement to demand explicit sign-off before an agent acts, so this delay doesn't open any window where AppH becomes “less compliant” than before.
Against / what doesn't apply
- This check only covers Chichi — if an AppH customer runs their own separate AI chat tool on their own site, outside AppManager, verifying their own Article 50 compliance is on them; AppH can't audit that for them.
- “Telling users they're talking to an AI” is just one obligation among several under the AI Act — it isn't full compliance, and the Annex III delay doesn't excuse anyone from tracking how the rules evolve if their business ever falls into high-risk-system territory.
We could have waited until 2 August to check whether Chichi meets Article 50. We did it this week instead, rereading the source code line by line, not trusting a memory of how the widget was built months ago. The gap between “we think we comply” and “we checked” is exactly the kind of gap this 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 customers, never intended to build an employee- or candidate-scoring system in the first place. The real question we ask any customer switching on an AI chatbot on their site hasn't changed, delay or no delay: does the person on the other end know they're talking to a machine, from the first line? If the answer is no, that isn't a compliance box to tick later — it's a lie of omission, and it stays one even without the AI Act.
Reviewed by a human at AppH