In 2026 the EU announced that implementation of the AI Act's high-risk system obligations, originally due June 2026, would be delayed to 2 December 2027 under the so-called Digital Omnibus. That sounds like a two-year reprieve. It isn't — only part of the law moved. The articles that touch most Dutch SMEs directly are already in force, and treating the whole Act as postponed is the mistake that costs businesses the most once the harder deadline actually arrives.
What the Digital Omnibus actually delayed
The Digital Omnibus pushed back the compliance deadline for high-risk AI systems — the category covering things like AI used in hiring, credit scoring, or safety-critical products — from June 2026 to 2 December 2027. If your business doesn't build or deploy that category of system, this particular delay barely touches you. What it does not do is pause the rest of the Act.
What is already in force, unchanged
- Article 4 — AI literacy. Organisations using AI must ensure staff have a sufficient level of AI literacy — understanding what the tools do, their limits, and the risks of misuse. This has applied since June 2026 and was not affected by the delay.
- Article 50 — Transparency. Sets requirements for how open and transparent AI systems must be toward the people affected by them — for example, disclosing when someone is interacting with an AI system rather than a person. In force since 2 August 2026.
Both obligations apply now, regardless of whether you touch high-risk AI at all. Most SMEs using AI tools in customer service, marketing, or internal operations fall under Article 4 at minimum.
Why the delay is worth using, not ignoring
Understanding and applying AI strategically is a competitive advantage on its own, separate from the compliance angle — but the delay specifically gives SMEs breathing room they should not waste. With the high-risk deadline no longer bearing down, this is the moment to get AI literacy training and transparency practices properly in place, instead of scrambling to do all of it at once when 2027 arrives. Businesses that use the extra time now avoid the costs and disruption of a last-minute push later, and get the customer-facing benefit of better AI practices in the meantime.
Practical steps for your business
- Invest in AI training for your staff to raise overall AI literacy — this satisfies Article 4 and pays for itself in better tool use.
- Review your current AI systems and put transparency practices in place to meet Article 50, particularly anywhere customers interact with an AI system directly.
- Use our free compliance scan to see exactly where you stand today and which of these obligations already apply to you.
At AI Advies Bureau we know this legislation is easy to misread as "delayed, so not urgent." Get in touch for specialised support to make sure your business is properly prepared — for what's due now, and what's coming in 2027.