90% probability EU AI Act GPAI enforcement powers and Article 50(1) interaction-transparency duties become applicable Aug 2 2026 — unpostponed by the Digital Omnibus. Scoped strictly: Article 50(2) AI-content watermarking has a grace period to Dec 2 2026 and is NOT included in this call.
EU AI Act timeline: GPAI enforcement and Art. 50(1) interaction-transparency disclosure apply 2 Aug 2026 per original schedule. The Digital Omnibus (provisionally agreed 7 May 2026, unadopted as of lock date) postpones high-risk AI system provisions to 2027/28 — GPAI and Art. 50(1) are unaffected. Art. 50(2) watermarking has a separate 4-month grace period to 2 Dec 2026 and is excluded from this call.
We lock a binary claim: EU AI Act GPAI (general-purpose AI) enforcement powers and Article 50(1) interaction-transparency disclosure duties become applicable on August 2 2026, unpostponed by the Digital Omnibus or any other amendment. Confidence 90%. Scope note: Article 50(2) AI-content watermarking has a 4-month grace period to December 2 2026 for systems placed on market before August 2 — it is explicitly excluded from this call and will not be scored against it.
The Digital Omnibus (provisionally agreed May 7 2026, unadopted at lock date) delays high-risk AI system obligations to 2027 and 2028 but leaves GPAI enforcement and Article 50(1) disclosure on the original Aug 2 2026 applicability date — confirmed by Gibson Dunn, Latham & Watkins, and Simmons & Simmons. Article 50(2)'s watermarking grace period (to Dec 2 2026) is a known carve-out and explicitly excluded from the scored criterion. Resolves against the EUR-Lex Official Journal and the European Commission AI Act page (digital-strategy.ec.europa.eu) on or before Aug 2 2026.
RAOSCAFF locks P-37 on 2026-06-21. Scope is explicit: GPAI enforcement + Article 50(1) only. Article 50(2) watermarking is excluded and will not be scored against this call.
Article 50(2) AI-content watermarking grace period to Dec 2 2026 is excluded from scope — it will not be scored against this call.