The EU didn't delay the rule that applies to your chatbot

In June 2026 the headlines said the EU was delaying the AI Act. That was half true. The half that was false is the half that covers the chat widget on your client's website.

What was actually delayed

The instrument is Regulation (EU) 2026/1744, the Digital Omnibus on AI, of 8 July 2026, published in the Official Journal on 24 July 2026. Most coverage dated it to the Parliament and Council votes in June; those were votes, not the act.

It moved two things:

Both are in Chapter III of the AI Act. Neither has anything to do with a chat widget.

Article 50 is in Chapter IV

The dates live in Article 113 of the AI Act. Its second paragraph reads, in full:

It shall apply from 2 August 2026.

Its third paragraph is a list of exceptions to that date, introduced by the word "However:". The Omnibus amends that third paragraph, at Article 1, point (40). It rewrites point (a), replaces point (c) with the 2027 and 2028 dates above, and adds a new point (d).

It does not touch the second paragraph. And it adds no exception covering Chapter IV, where Article 50 sits.

That is the whole argument. It is not an inference from commentary — it is the exhaustive reading of the only provision that could have delayed Article 50.

The Omnibus does amend Article 50 — once

Search the enacting terms for "Article 50" and you get two hits. One is an incidental cross-reference. The other is Article 1, point (20):

in Article 50, paragraph 7 is replaced by the following: '7. The Commission shall encourage and facilitate the drawing up of codes of practice at Union level…'

Paragraph 7 is institutional plumbing about who convenes codes of practice — the job moves from the AI Office to the Commission. Paragraphs 1 to 6, every operative obligation, are untouched.

The Commission says the same thing

You do not have to take our reading of it. The Commission's own guidelines, adopted 20 July 2026, say at paragraph (153):

According to Article 113 AI Act, Article 50 AI Act will apply as from 2 August 2026. This requires all in scope AI systems placed on the market or put into service in the Union to be compliant with that provision on that date, regardless of their date of placement on the market or putting into service.

The one real relief, and its exact limits

There is a transitional rule, and it is narrower than most summaries suggest. The Omnibus adds a new Article 111(4):

Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, that have been placed on the market before 2 August 2026 shall take the necessary steps in order to comply with Article 50(2) by 2 December 2026.

Which means:

• It covers Article 50(2) only — machine-readable marking of generated output.
• It covers only systems already on the market before 2 August 2026. Ship something new after that date and it marks output from day one.
• Article 50(1), (3) and (4) get no transition at all.

And for the case most agencies actually have — a chat widget that both talks to people and generates text — the Commission closes the door explicitly in the same paragraph (153): systems that are partly interactive and partly generative benefit from the transitional period only with regard to the marking obligation, while the disclosure obligation for direct interaction must be met from 2 August 2026.

Verify this yourself

1. Open Regulation (EU) 2026/1744 and search the enacting terms for "Article 113". Read point (40).
2. Open Regulation (EU) 2024/1689 and read Article 113. Note which chapters appear in the exceptions.
3. Open the Commission guidelines and read paragraph (153).

Three documents, ten minutes. That is the standard we hold ourselves to.

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