The Digital Omnibus on AI entered into force on July 27, and the headline everyone read was that Europe has softened its AI rules. It has. The European Union's high-risk obligations moved out by up to sixteen months: to December 2, 2027 for standalone systems in areas like hiring and credit, and August 2, 2028 for AI embedded in regulated products like medical devices and machinery. If your company builds AI into a regulated product, that is real relief.

What almost nobody has been told is that the transparency rule was not moved at all. Article 50 applies on August 2, 2026. The European Commission confirmed it in a single sentence in its own guidance, and published a full set of interpretive guidelines for it on July 20 — which is not what regulators do a fortnight before a deadline they intend to postpone.

Breaches sit in the second ...