The AI deadline moved to December 2027. What it does not buy you.

A delay is the easiest news in regulation to misread, because the headline is a date and the substance is a list. Here is the list.

Why a UK broker should read this at all

Three reasons, in descending order of likelihood.

Your vendor is in scope even if you are not. The AI Act binds providers placing systems on the EU market. A UK firm buying a tool from a European provider, or from an American one that sells into Europe, is buying a product whose roadmap is now shaped by December 2027 rather than August 2026. Features you were told would arrive with the compliance release have just been given sixteen more months of runway. Ask.

Some of you do sell into the EU. A UK firm with Irish clients, or a product with European users, can be a deployer of a high-risk system under the Act. Recruitment screening and credit scoring are both named Annex III uses, and both are things small professional firms now do with software they did not write.

And the transparency rules are the ones that bite in public. Telling a person they are talking to a machine, and labelling synthetic content, are the obligations a customer can observe. They did not move.

What we would actually do with sixteen months

Not wait. The classification work — deciding which of your systems, if any, are high-risk, and writing down why — is the part that takes calendar time rather than effort, because it needs decisions from people who are busy. It also does not expire. A system inventory written this autumn is still correct in 2027, whereas a compliance sprint started in October 2027 will discover in week two that nobody knows which model the recruitment tool uses.

1. List the systems, not the vendors. One vendor can supply three systems with three different risk profiles. The stack check exists because most firms cannot answer "what is actually running" without looking.
2. Write down the use, in a sentence, for each. Annex III is a list of uses, not of technologies. "Ranks job applicants" is in scope; "drafts a job advert" is not.
3. Ask each provider, in writing, what changed for them when the Omnibus became law. The answer tells you whether they have a compliance function or a marketing page.
4. Do the transparency work now, because it is small and it is due. If a customer can talk to something of yours, it should say what it is.

The status, stated honestly

It is law. The provisional agreement reached in the early hours of 7 May 2026 and confirmed by Member State representatives on 13 May was adopted as Regulation (EU) 2026/1744 of 8 July 2026, published in the Official Journal on 24 July and in force since 27 July 2026, a week before the 2 August deadline it was designed to relieve. The dates above are the regulation’s.

This note was first published describing it as a provisional agreement, from a law firm’s reading in May, two months after it had become law — which is the kind of thing the register exists to record, and it does.

If you want the general version of this argument — that the thing to buy is not the model but the record of what it did — it is in the audit trail note, and the commercial version is in how AI vendors price. Our own view of which claims from AI vendors survive checking is the same exercise on five published AI claims.