N° 0026 · Regulatory Deadline · Updated 29 June 2026
The clock stopped moving.
On 29 June 2026 the Council gave final adoption to the Digital Omnibus. Annex III high-risk obligations, including Article 12 logging and Article 9 risk management, are now fixed at 2 December 2027. Article 50 transparency obligations and enforcement powers remain live from 2 August 2026. What does your evidence look like?
Article 50 transparency · enforcement powers active
Active and imminent obligations: regulated financial institutions
Providers and deployers must maintain technical documentation of training, testing, and capabilities. Applicable since 2 August 2025.
KairoNull: can record the model name and version your system reports with each event. It does not produce the technical documentation.High-risk AI systems must automatically log events throughout their operational lifetime to ensure traceability of output. Now fixed at 2 December 2027 for standalone high-risk (Annex III) systems, following the Council's final adoption of the Digital Omnibus on 29 June 2026.
KairoNull: a SHA-256 hash-chained ledger of the events your system sends. Whether that meets Article 12 for your system is a legal and technical question this page does not answer.Deployers of high-risk AI must establish, implement, document, and maintain a risk management system throughout the AI lifecycle. Now fixed at 2 December 2027 for standalone high-risk (Annex III) systems, following the Council's final adoption of the Digital Omnibus on 29 June 2026.
KairoNull: can record the policy results your system reports as events. It does not perform or document risk management.AI systems interacting with humans and generating synthetic content must disclose their AI nature. Violations under Art. 99(4): up to €15M or 3% of global annual turnover.
KairoNull: can record that a disclosure event happened, if your system reports it. It does not generate the disclosure.Full obligations for credit scoring, employment decisions, and insurance risk assessment systems. Fixed by Council's final adoption of the Digital Omnibus, 29 June 2026.
KairoNull: a record exists only from the point your system starts sending events; it cannot be created retroactively.FCA-regulated firms must evidence who owns AI-enabled processes, what controls apply, and how performance is monitored.
KairoNull: records the events your system reports. This is not a mapping to FCA expectations.Organisations making automated decisions with legal effects must document the logic, significance, and envisaged consequences.
KairoNull: records the policy id, version and outcome your system reports per event. The logic documentation remains yours.Quick risk assessment: regulated financial services
What does your AI system primarily do?
2 December 2027 is a fixed date now, not a political guess.
Most compliance programs will start planning in Q3 2027, when the runway is gone. Build the evidence layer now, while you have room, so December 2027 is a confirmation, not a scramble.
Evidence has to exist before it is asked for: a record cannot be created after the fact.