The deadline that did not move: the Digital Omnibus postponed the Annex III high-risk deployer obligations to 2 December 2027 — but Article 50 transparency obligations still apply from 2 August 2026 (Regulation (EU) 2024/1689, Art. 113; European Parliament, 16 June 2026 vote). If you deploy chatbots, candidate-facing AI communication or AI-generated content, the disclosure duties land this summer, Omnibus or not.
What Article 50 requires
If your organization deploys AI systems that interact directly with people (HR chatbots, screening assistants, support bots) or generate synthetic content, you must ensure users are informed they are interacting with AI, and that AI-generated or manipulated content is disclosed as such. Non-compliance falls under the Article 99(4) fine bracket: up to €15 million or 3% of global annual turnover, whichever is higher.
Where the timeline stands (verified July 2026)
The Digital Omnibus was approved by the European Parliament on 16 June 2026 and by the Council on 29 June 2026. It awaits publication in the Official Journal (expected July 2026). Until publication, the original deadlines remain the law — and even after publication, Article 50 keeps its 2 August 2026 date. Only the Annex III high-risk deployer obligations (recruitment, worker management, etc.) move to 2 December 2027.
Your realistic options
1. Wait for enforcement clarity. National market-surveillance regimes are still maturing, but the obligation is directly applicable from 2 August 2026. Waiting means your sales counterparties — increasingly asking Article 50 questions in security questionnaires — get "no" as the answer. Free, but commercially costly.
2. DIY from the regulation. Read Article 50, map your AI touchpoints, write the disclosures and log the decisions. Realistic for teams with legal capacity; typically several working days plus upkeep. Cost: internal time only.
3. GRC subscription platforms (Vanta, Drata, Secureframe). Strong for continuous, certification-driven programs; AI Act coverage is developing and contracts are annual subscriptions (typically $4,000–$80,000/year depending on scope). Oversized if what you need is a one-off, deadline-driven evidence pack.
4. Law firm or Big-4 memo. Bespoke and authoritative; typical projects run €10,000–40,000+ and produce advice rather than reusable, verifiable evidence artifacts.
5. Fixed-price evidence pack. PowerQuant (that's us — judge accordingly) produces deployer-oriented, cryptographically signed Article 50 + NIS2 evidence at a fixed price, built for the questionnaire moment: what your customers actually ask, answered with verifiable artifacts. Start with the 2-minute scope check to see whether you are in scope at all.
Comparison
| Option | Cost | Time to evidence | Reusable artifacts |
|---|---|---|---|
| Wait | €0 | — | No |
| DIY | Internal time | Days–weeks | Depends on rigor |
| GRC platform | $4k–80k/yr | Weeks | Yes (subscription) |
| Law firm | €10k–40k+ | Weeks | Advice, not artifacts |
| Fixed-price pack | Fixed one-off | Days | Yes, signed |