EU AI Act: the high-risk deadline moved. The logs question did not.
The Digital Omnibus on AI was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. It moves the obligations for stand-alone high-risk AI systems, the ones listed in Annex III of the AI Act, from 2 August 2026 to 2 December 2027, and for high-risk systems inside regulated products to 2 August 2028.
Annex III includes AI systems used to evaluate the creditworthiness of people or set their credit score. For those, Article 26(6) of the AI Act asks deployers to keep the logs the system generates for at least six months; deployers that are financial institutions keep them as part of the documentation their financial services law already requires.
The extra sixteen months change when the question is asked, not what it is. When a supervisor or a customer asks why the system decided what it did, will your logs show what happened, or only what your own system says happened?
This is a reading of the regulation and of public summaries of it, not legal advice.
Sources: Lewis Silkin, 27 July 2026, https://www.lewissilkin.com/insights/2026/07/27/the-digital-omnibus-on-ai-enters-into-force-today-102nedo ; Regulation (EU) 2024/1689 (AI Act), https://eur-lex.europa.eu/eli/reg/2024/1689/oj