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The EU AI Act after the Digital Omnibus: which obligations already apply to chatbots and voice agents, and which were postponed

The European Union adjusted its Artificial Intelligence Act with the so-called Digital Omnibus, which postponed the rules for high-risk systems until 2027 and 2028. But the obligation to tell people they are talking to an AI did not move: it has applied since August 2, 2026, and the next deadline arrives on December 2.

By the 19 80 TIC Cloud team··3 min read
The EU AI Act after the Digital Omnibus: which obligations already apply to chatbots and voice agents, and which were postponed

What the Digital Omnibus is and what changed

The European Union's AI Act came into force in 2024 with a phased schedule of obligations. In November 2025, the European Commission proposed simplifying it as part of a package called the Digital Omnibus. According to the law firm Cooley, the final text was agreed on June 29, 2026, was published in the Official Journal as Regulation (EU) 2026/1744 and entered into force on July 27, 2026, as Hunton also confirms.

The main postponements are:

The Omnibus also extended SME benefits to mid-sized companies and softened the staff AI literacy obligation, which the Commission and member states must now support.

What was not postponed: telling people they are talking to an AI

Article 50 of the law sets transparency obligations that have applied since August 2, 2026, and the Omnibus did not move them. The one that matters most to anyone serving customers is Article 50(1): if an AI system interacts directly with people, such as a customer service chatbot or a voice assistant, the person must know they are talking to a machine.

The Commission's guidelines on Article 50, published on July 20, 2026, and summarized by the law firm McCann FitzGerald, clarify how to comply:

Fines for breaching the transparency rules can reach €15 million or 3% of worldwide turnover, whichever is higher.

What comes in December 2026

The next milestone is December 2, 2026. On that day the transition period ends for generative AI systems that were already on the market before August to mark their synthetic content (audio, image, video or text) in a machine-readable way, according to the Commission and the guidelines. To support that marking, the Commission published a voluntary code of practice in June 2026.

On that same day, new prohibitions added by the Omnibus take effect: AI systems designed to generate non-consensual intimate images and child sexual abuse material.

In short, the calendar looks like this: transparency toward users from August 2026, content marking for older systems and new prohibitions from December 2026, high-risk systems from December 2027 and AI in regulated products from August 2028.

For a voice agent this means two things: say from the very first moment that it is an AI and, if it generates synthetic audio, have the technology provider mark it according to the rules.

What it means for businesses in Colombia and Latin America

The EU AI Act can reach companies outside Europe when their systems are offered in the Union or their outputs are used there. But even if your company only serves customers in Colombia, the European law is a good best-practice handbook:

At 19 80 TIC Cloud we set up AI voice agents and 24/7 chat that introduce themselves as AI and hand the conversation over to a human advisor when the customer needs it.

We help you implement it

Want to bring this to your company?

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Sources

  1. Cooley: Digital AI Omnibus delays key deadlines, introduces new rules
  2. Hunton: EU Digital Omnibus on AI enters into force
  3. McCann FitzGerald: AI Transparency, European Commission's Guidelines on Article 50
  4. Comisión Europea: Code of Practice on transparency of AI-generated content (FAQ)
  5. Legalithm: EU AI Act, what applies on 2 August 2026
  6. Technology.org: EU AI Act deadlines after the Digital Omnibus
We answer your questions

Frequently asked questions

Did the Digital Omnibus postpone the obligation to disclose that a chatbot is an AI?

No. The Article 50 transparency obligations have applied since August 2, 2026. What was postponed were the rules for high-risk systems, until December 2027 and August 2028.

How should a voice agent disclose that it is an artificial intelligence?

The Commission's guidelines don't impose a format, but they require informing people clearly, at the latest at the first interaction. On a call, a spoken notice at the beginning meets that idea. In addition, the system must acknowledge that it is an AI if asked.

Does the EU AI Act apply to Colombian companies?

It can apply if the company offers AI systems in the European Union or if the outputs of those systems are used there, for example when serving European customers. If it only operates in Colombia, it doesn't apply directly, although it is a good practice guide.

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