Every high-risk compliance plan built before this summer now carries at least one wrong date. The obligation for standalone high-risk systems was pinned to 2 August 2026 across countless slide decks and gap assessments. It is now 2 December 2027.
The honest way to present this is to show both dates, with the old one struck through. A schedule that silently overwrites the pre-Omnibus deadline gives no way to check whether a document predates the reform or simply ignores it.
There is a trap inside the relief. A conditional early-application mechanism lets the Commission bring high-risk rules forward if it confirms that standards and tooling are ready. The December 2027 and August 2028 dates are backstops, not guarantees of a full runway.
Analysis is original writing by the euaicompliant desk. Not legal advice — the binding text is on EUR-Lex.