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The EU AI Act after the Digital Omnibus: what SMEs need to know

New deadlines for high-risk AI, a softened AI literacy duty and transparency obligations: where the EU AI Act stands for mid-sized companies.

By Frank Maier · Last checked: 4 October 2026 ·2 min read

The EU regulation on artificial intelligence (AI Act) applies in stages. With the so-called Digital Omnibus, the Council and Parliament agreed on simplifications and new deadlines on 7 May 2026. For most mid-sized companies that is good news – but not a free pass.

What has changed

  • High-risk AI later: Obligations for high-risk systems under Annex III (for example AI in recruitment, education or critical infrastructure) only apply from 2 December 2027, and for AI in regulated products under Annex I from 2 August 2028.
  • AI literacy softened: Providers and deployers now have to “support” the development of their staff’s AI literacy. A specific level for every individual no longer has to be guaranteed.
  • Transparency already applies: The transparency obligations under Article 50 – such as telling users they are interacting with an AI, or labelling AI-generated content – have applied since 2 August 2026.

What this means for typical SMEs

If you use AI assistants such as Microsoft Copilot or ChatGPT in day-to-day work, or automate processes with language models, you are as a rule not running a high-risk system. What mainly matters is:

  1. Transparency: Chatbots on your website and AI-generated text and images must be recognisable as such.
  2. Literacy: Staff should know what AI can do, where it makes mistakes and which data they must not enter. A short, documented training session remains worthwhile.
  3. Data protection: The GDPR applies regardless of the AI Act. What matters is server location, data processing agreements and whether inputs are used for training.

A pragmatic start

Instead of starting with legal clauses, we start with your processes: in a use-case workshop we find out where AI really saves time. We then introduce suitable tools – self-hosted in the EU if you prefer, for example with n8n as the automation platform – and train your team.

This article is not legal advice.

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