The EU's high-risk AI deadline just passed. The assumed delay may not have landed
On 2nd Aug’26, the EU AI Act's obligations for high-risk systems — the ones used in hiring, lending, infrastructure and healthcare became due. A last-minute 'Omnibus' package to push the hardest parts back to late 2027 was negotiated, but it only takes effect if it was formally adopted before that date. As of this week, if it wasn't, the original rules apply as written, including Article 15, which now demands documented evidence that a system resists adversarial inputs, data poisoning and manipulation.
What it actually means
A lot of teams have been building on the assumption the deadline slipped. That's now a bet, not a fact and it's the wrong one to make quietly. If anything you ship touches an EU hiring, credit, infrastructure or health decision, the obligation isn't 'have a responsible-AI page'; it's 'show your working'. So, logs of what the model saw and decided, and proof you've tested it against someone trying to trick it. Start the evidence file now, because the fine ceiling here isn't a slap, and 'we thought it was postponed' isn't a defence.
The postponement everyone planned around only counts if it was actually signed. Don't bet your compliance on a headline.
€35Mthe EU AI Act's top fine, or 7% of global turnover, whichever is larger
Source: Gibson Dunn · Tuesday 4 August 2026