The Digital Omnibus proposes delaying the AI Act's high-risk obligations, not Article 4, which has applied since 2 February 2025, so any plan to defer AI literacy work is misplaced.
The most common thing I hear at the moment, usually with visible relief, is that the AI Act has been pushed back and there is now time.
Something was pushed back. It was not the part that applies to you.
The Digital Omnibus proposals concern the high-risk obligations in Chapter III: the conformity assessments, technical documentation and post-market monitoring that attach to organisations building or deploying AI systems in the Act's high-risk categories. The proposal extends their application from 2 August 2026 to 2 December 2027.
If you run a recruitment scoring system, biometric identification, or an AI system making decisions about access to essential services, that timeline matters to you enormously.
Article 4 sits in Chapter I. It has applied since 2 February 2025. It is not in the delayed set.
This is not a technicality. The Act is structured so that a small number of general provisions apply to everyone, and a much heavier regime applies to a defined set of high-risk uses. Chapter I is the "everyone" part. The delay is to the "defined set" part.
An organisation using a chatbot to draft donor reports was never in Chapter III. It was always in Chapter I. Nothing about its position changed.
Coverage of the Omnibus said "the AI Act has been delayed", which is a fair headline about the most commercially significant provisions and a misleading one about scope. If your only exposure to the Act is Article 4, that headline told you the opposite of the truth.
There is also a more human reason. Article 4 is the obligation that is easy to ignore, because nothing happens immediately if you do. A delay story gives permission to keep ignoring it.
Practically, only one:
Do you start now, or in the next budget cycle?
If you believed the obligation moved to December 2027, deferring to the next cycle looked prudent. It is not prudent; it is a decision to remain unable to answer a funder's question for another year.
The Omnibus is a proposal, and proposals change during the legislative process. The Chapter III dates I have given are the proposed dates, not settled law. If your exposure is in Chapter III, track it properly and take advice, and do not plan against a summary.
For Chapter I, the position is simpler: it has applied since February 2025 and no proposal I am aware of moves it.
If someone in your organisation has said "the AI Act got delayed, so we have time", find out which chapter they mean. In almost every mission-driven organisation I have seen, the answer is that they read a Chapter III headline and applied it to a Chapter I obligation.
The correction takes one sentence. The consequence of not making it is a year.
If this is the question on your desk, a thirty-minute call tells you whether the service fits, or that you do not need us yet.