The Digital Omnibus changes the EU AI Act. But not in the way you think.

You will be reading about it in the coming weeks: the EU AI Act is being "simplified". The Digital Omnibus has been adopted by the European Parliament and the Council, and once publication in the Official Journal is complete, the law will change on several points. The predictable reaction in many a management meeting: good, that AI file can wait a little longer. That is precisely the wrong conclusion. Let me explain why.

What actually changes

The Digital Omnibus on AI was approved by the European Parliament on 16 June 2026 and received the Council's final green light on 29 June 2026. It now awaits publication in the Official Journal. The Omnibus covers more than most summaries mention, from a new prohibition on AI that generates non-consensual intimate imagery to adjustments to the high-risk definition. But two changes matter to almost every organisation.

One: the deadlines for high-risk AI shift, depending on the category, to December 2027 or August 2028. Anyone using or providing high-risk systems gets more time.

Two, and this affects everyone: Article 4 on AI literacy has been rewritten. The original text asked organisations to ensure, to the best of their ability, "a sufficient level of AI literacy" among their staff. An outcome-oriented wording: the emphasis was on the level your people were supposed to reach. The new text asks organisations to "take measures to support the development of AI literacy", fitting role, experience and context, and explicitly without any guarantee that a given individual reaches a specific level of knowledge. A deliberate effort obligation, in other words.

What does not change

Article 4 has not been given a new application date: the obligation has applied since 2 February 2025 and continues to apply. Only its wording changes once the Omnibus enters into force. The duty to actually do something about AI literacy does not disappear, it is phrased differently. The prohibited AI practices also remain in place, and one is even added. And while the high-risk deadlines move back, supervision moves the other way: member states are designating their supervisory authorities, and from 2 August 2026 supervision becomes operational.

Anyone reading the Omnibus as a stay of execution is reading it wrong. The obligation that touches your entire organisation has not been postponed.

Why an effort obligation is anything but optional

Let's be honest: on the outcome side, this is a relaxation. The guarantee of a knowledge level per employee is gone. But anyone concluding that the duty has become optional is missing where the centre of gravity shifts.

The old standard was strictly worded but hard to pin down in practice. Because what is "a sufficient level"? That had not yet been sharply defined in binding guidance, and that vagueness left room to wait and see. The new text is worded more mildly but is more concrete in what it asks of you: measures. And measures you cannot demonstrate carry hardly any weight as evidence of compliance in supervision or an audit. In practice, your evidential position therefore shifts to documentation: whoever takes measures must be able to show which ones, for whom, when, and why they fit the role and context. The key word is no longer "sufficient". The key word is "demonstrable".

What such measures look like is deliberately not prescribed by the law. No mandatory exam, no mandatory certificate, no fixed format. But in practice, they are no mystery. Think of an inventory of which AI is used in your organisation. Training that fits role and risk, from the front desk to senior management. An exam with a certificate, not because it is required but because it is strong evidence that the measure is serious, verifiable and role-specific. And refreshers whenever the tools or the rules change. Anyone who has that in order can answer any question from a supervisory authority, auditor or insurer with a file instead of a promise.

So the bar does not disappear. It shifts: from what your people have in their heads to what you can show you have done for them.

What this means for your approach

Three things, briefly.

Pause nothing. The obligation has applied since February 2025, and from 2 August 2026 supervision will be running. Whoever starts now is ready before the first questions arrive.

Documentation becomes the core. Every measure you take must be traceable: who was trained, on what, when, with what result. Evidence is the product of your effort.

Keeping it up is part of it. An effort is not a one-off action. New tools, new employees and new rules call for a recurring rhythm. How to set up that rhythm in practice is something I described earlier this week in a separate Insight on AI policy in practice.

The Digital Omnibus is no reason to sit back. It is the legislator writing down more precisely what was always expected of you: show that you take your people seriously in a working environment where AI is not going away.

Frequently asked questions

Has Article 4 of the EU AI Act been abolished?

No. Article 4 has applied since 2 February 2025 and continues to apply. The Digital Omnibus rephrases the duty from an outcome-oriented wording to a deliberate effort obligation: taking measures to develop AI literacy, demonstrably and fitting role and context.

Does the EU AI Act still apply?

Yes. The Omnibus amends parts of it, shifts the high-risk deadlines to December 2027 or August 2028 and even adds a new prohibition. The law itself remains in force, including the prohibited AI practices and the literacy obligation.

When does the Digital Omnibus take effect?

The Omnibus was adopted in June 2026 by the European Parliament (16 June) and the Council (29 June). The changes enter into force on the third day after publication in the Official Journal of the EU. Until that publication, the original text of the AI Act formally applies.

Rob Ummels, AIAdopt. AI adoption, AI literacy and practical guidance for organisations that want to use AI wisely.

Written by Rob Ummels in collaboration with Claude (Anthropic). Final editorial responsibility: AIAdopt.