Is the AI Act postponed? Yes and no.
The "Digital Omnibus" pushed back several AI Act deadlines — but some obligations apply right now to a connected product. Here is which ones, and from when, for a manufacturer.
The timeline, after the Digital Omnibus
Am I concerned?
| Your situation | Deadline |
|---|---|
| Your product or app includes a chatbot, a voice assistant or generates content | Now (Art. 50) |
| Product already subject to CE marking (machinery, radio, medical…) with an AI function | 2 August 2028 |
| Use in HR, credit/insurance, education, critical infrastructure, justice | 2 December 2027 |
Indicative screening — the firm legal qualification is a matter for qualified counsel.
One project for two regulations
The CRA applies from September 2026, the AI Act after that. Good news: their requirements overlap by ~60% (risk analysis, technical documentation, logging, incident notification…). Done well, most of your CRA effort counts twice.
FirmVox computes the real overlap rate for your product, in the report.
Where do you stand?
A free assessment tells you, in 20 minutes, what applies to your product — CRA and AI Act — with the deadlines and an action plan.
Start the free assessment11 September 2026 for an SME
The first CRA deadline, what it actually requires of a twenty-person manufacturer, and the reporting checklist to put in place beforehand.
CRA product classes
Class I, class II, critical products: what decides which regime applies to your product — and whether a notified body is involved.
Manufacturer, importer, distributor
The CRA allocates obligations by economic role. Here are yours, article by article.
CRA deadlines
11 June 2026, 11 September 2026, 11 December 2027: what applies when, and how to plan backwards from it.
SBOM and the CRA
What Annex I actually requires of a software bill of materials — and what it does not.
Technical documentation and conformity
Annex VII, the Article 32 procedures, and when self-assessment remains possible.
Informational content — not legal advice. The deadlines from the "Digital Omnibus" are subject to change; check the official text of Regulations (EU) 2024/2847 (CRA) and 2024/1689 (AI Act).