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EU AI Act Deadlines Moved, but Board Duties Didn’t

By Markus Bernhardt

08/11/2026

Artificial Intelligence Compliance Member-Only
Key Points
  • Several EU AI Act requirements, including Article 50 transparency disclosures and the prohibited-practice regime, remain fully in force and demand immediate board action regardless of other deadline extensions.
  • The additional months the deferral provides are not a reprieve; they are the window for boards to close compliance gaps before regulators force the issue.
  • Assigning a named owner to each consequential AI system and establishing an approval record are concrete, achievable first steps the board can oversee.

This AI-generated summary, based on content on this page, was reviewed by NACD editors for accuracy.

The Digital Omnibus on AI extended certain EU AI Act deadlines, but the obligations that carry the greatest governance risk for boards remain.

On June 29, 2026, the Council of the European Union (EU) approved the Digital Omnibus on Artificial Intelligence, and with it a set of postponements many boards had been waiting for. The high-risk AI obligations set to apply on Aug. 2, 2026, under the EU AI Act were pushed back.

Rules for standalone systems, such as recruitment, credit-scoring, and border-control tools, now apply from Dec. 2, 2027. Rules for high-risk AI embedded in regulated products move to Aug. 2, 2028. Most boards have taken these postponements as a reprieve.

That relief is understandable, but it ...

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Markus Bernhardt

 

 

Markus Bernhardt, PhD, is principal of Endeavor Intelligence, an independent research and advisory practice. He advises enterprise leaders and boards globally on AI strategy and organizational transformation.

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