The EU just delayed parts of the AI Act: what changes for Swiss companies
In October 2026 the EU formally adopted the "AI Omnibus", amending the AI Act. The headline change for Swiss companies: the strictest rules for high-risk AI systems now apply from 2 December 2027 (stand-alone systems) and 2 August 2028 (systems embedded in regulated products) - not from August 2026 as originally planned.
What changed
High-risk rules delayed: stand-alone high-risk AI systems (Annex III) move to 2 December 2027; high-risk AI embedded in regulated products to 2 August 2028.
Transparency still applies: the Article 50 transparency obligations - marking AI-generated content, disclosing when people interact with an AI - started on 2 August 2026 and were not delayed. A transitional deadline for marking synthetic content from systems placed on the market before 2 August 2026 runs to 2 December 2026.
New prohibition added: the Omnibus bans AI practices that generate non-consensual sexual or intimate content or child sexual abuse material.
Simplification: extended simplified documentation for medium-sized companies, clarified AI Office powers, and a mechanism to avoid double regulation where sectoral law (machinery, medical devices) already covers AI risks.
What did not change
The prohibited-practices bans (in force since February 2025).
The general-purpose AI model obligations and governance framework (in force since August 2025).
The penalty regime: up to the higher of EUR 35 million or 7% of worldwide annual turnover.
The extraterritorial reach: Swiss providers serving the EU market, or whose AI output is used in the EU, remain in scope.
The practical read for Switzerland
The delay is breathing room, not an exemption. If your product could be high-risk under Annex III (HR screening, credit scoring, education admissions, critical infrastructure, and similar), 2027 arrives fast - conformity work takes quarters, not weeks. And because transparency duties already apply, Swiss companies deploying chatbots or generating synthetic content for EU users have obligations today.
Sources
European Parliament Legislative Train, "Digital Omnibus on AI"
EU AI Act Service Desk, "Timeline for the Implementation of the EU AI Act"
Last updated: 20 October 2026.
Not sure what the AI Act timeline means for your product? We help Swiss companies plan the work before the deadline plans it for them.
