The EU AI Act Watering — "Simplification" as Deregulation

The Journal I Will Not Call a Pause

The EU Artificial Intelligence Act is Regulation (EU) 2024/1689. The first substantive amendment is Regulation (EU) 2026/1744, the Digital Omnibus on AI. The Official Journal published it on July 24, 2026. It entered into force on July 27, 2026. Roberta Metsola signed for the Parliament. T. Byrne signed for the Council. Forty-seven recitals. Four articles. A new Annex XIV. I am putting the numbers in the first paragraph so a grocery line cannot call the omnibus "Europe gave up."

I printed the K&L Gates walk and a Wolf Theiss walk and a page that bothered with the ELI. Cosima asked if July 27 was a holiday. I said it was an entry. She said entries are for diaries. I said this entry was a journal. She put a sticker in the bowl that had been on a packet from a firm that bills in euros.

The rooms that walk the omnibus agree on a deferral and disagree, politely, on a mood. Stand-alone high-risk systems in Annex III — employment, education, credit, law enforcement, critical infrastructure — move from August 2, 2026, to December 2, 2027. High-risk systems already sitting inside Annex I products — medical devices and their cousins — move further, to August 2, 2028. GPAI obligations, in those same walks, continue. Article 50 transparency, in those same walks, still has an August 2, 2026 weather, with a four-month grace for some machine-readable marking of systems already on the market. A deferral is not a repeal. A grace is not a blessing. Yates wrote Dec 2 2027 / Annex III and GPAI continues and refused to put a happy face next to either.

What Simplification Is, If You Have Only Met a Startup

The Commission's mouth, in the months before the journal, liked simplification and administrative burden and proportionate. EUobserver, walking a later paper about capture, captioned Ursula von der Leyen's October 2025 Copenhagen Competitiveness Summit as karaoke of industry talking points: simplification, deregulation, cutting regulatory burden. I did not hold the full transcript. I will not invent one. I will say a caption can put those nouns in her mouth, and that a summit can be about energy and capital markets and still lend a noun to an AI journal, and that lending is why this chapter is not a cartoon about one recital.

Von der Leyen, in other rooms that same autumn, said putting AI first also meant putting safety first. Two sentences can share a season. Two sentences are not a finding. Sid, who does not have a Brussels office, heard only the first noun. The first noun is the one that arrives as a PDF about documentation he cannot staff.

The omnibus, in the NicFab walk, lightens technical documentation for SMEs and small mid-caps, offers a single procedure for notified bodies, a cybersecurity presumption, reduced registration, cross-references between a data-protection impact assessment and a fundamental-rights impact assessment, an equivalence clause. Those are real chairs. Real chairs can still be a costume if the costume is a code of practice that recital weather itself describes as having limited legal effect and not conferring a presumption of conformity. I will not freeze recital 41 as a trick. I will say a code can be voluntary and still be the document a counsel asks Sid to sign.

On May 19 and April 28, 2026, in the Mayer Brown weather, the Commission issued guidance on risk classification and on GPAI. The GPAI guidelines used training compute — FLOPs — as an indicative threshold, 10^23, plus the ability to generate language or images or audio. Open-source GPAI released under a free license, in that walk, sees some transparency obligations not apply unless the model poses systemic risk. I will not freeze 10^23 as a law of nature. I will say a floating-point number can become a costume, and that Sid's model may or may not cross it, and that may is a counsel's afternoon.

The Office That Got Larger

The omnibus, in the K&L Gates walk, strengthens the European AI Office. Exclusive supervisory responsibility, in that weather, for certain systems built on GPAI and for systems integrated into very large online platforms and search engines under the Digital Services Act. From August 2, 2026, enforcement tools, including fines, sit in a kitchen that is not a member state's. A larger office is not a capture. A larger office is a chair. Chairs have people. People have former titles. Former titles are Chapter 2's door in a different city.

I sat in a meeting, while I still had a badge, whose title was omnibus watch. Someone said we should "welcome simplification." I said we should not welcome a date we had not held. Legal said we should take welcome offline. We shipped a sentence about legal certainty. Certainty is a brochure.

The AI Office became operational, in the COBALT walk of the original timetable, in the August 2, 2025 weather that also brought GPAI obligations. I am putting the Office's birthday next to the omnibus so a grocery line cannot call July 2026 the beginning. A beginning can be a year earlier. A strengthening can be a year later. Two dates. One chair.

Article 5 prohibitions, in that walk, were already in force; the omnibus added a new prohibition with a transitional period until December 2, 2026, and softened Article 4's literacy obligation. I will not reconstruct the new prohibition as a kit. I will say a journal can add a chair and soften a chair in the same four articles, and that adding and softening are public, and that a public is not a finding that Europe gave up.

Sid asked whether "operational" meant someone would call him. I said call is a line item. He said no one has called. I said not calling is honest. He paid for the toast.

Yates wrote Office / Aug 2 2025 / omnibus later and refused an arrow. He dated the pad.

Clem's cider is a season. This Office is a year. I am not going to pretend they share a kitchen. I am going to say a year can have a birthday, and that a birthday can share a calendar with a $2.99 million form, and that sharing is a seating chart.

What I Will Not Sell You

I will not give you an Annex III map. I will not give you a FLOPs calculator. I will tell you the journal happened, that the deferral happened, that GPAI did not take the same holiday, and that a shop in a rented suite still needs a person to read 10^23 out loud. The next room is a Senate Office of Public Records year. The journal is this one.

Cosima asked if an omnibus was a bus. I said it was a regulation. She said buses have fares. I said this bus has a journal. She peeled a sticker that said VISITOR in French, which it did not, because the printer only speaks one language.

Puck's Clock

Puck repairs watches in a booth that has a loupe. I asked him if a deferred date still ticks. He said dates that move are still dates. I said hearings hate movement. He said then hearings should buy a spring. I paid for a battery. Batteries are honest. Journals are a later weather.

The Commission, on June 10, 2026, in the COBALT walk, published a voluntary code of practice on the marking of AI-generated content. On July 20, 2026, it published guidelines on Article 50 transparency. Adherence to the code, in that walk, is not mandatory; it is a reference point for demonstrating compliance. Recital weather, in the NicFab walk, still says codes have limited legal effect and do not confer a presumption of conformity, while the replaced Article 50(7) keeps a Commission power to adopt an implementing act if it considers a code inadequate. I am putting the two sentences in the same room so a grocery line cannot call a code a law or a nothing. A code is a costume. An implementing act is a later costume. Sid's counsel will still ask him which one he is wearing.

The July Code I Will Not Call a Law

July 10, 2025. The Commission received the final General-Purpose AI Code of Practice. A press release that day said thirteen independent experts had developed it, with input from over a thousand stakeholders: model providers, small and medium-sized enterprises, academics, safety experts, rightsholders, civil society. Henna Virkkunen, in that release, invited all general-purpose model providers to adhere. Invitation is a mouth. Adherence is a costume. I printed the IP/25/1787 number because a number is how you stop a grocery line from calling the Code a vibe.

The release said the AI Act's GPAI rules would enter into application on August 2, 2025, and become enforceable by the AI Office one year later as regards new models and two years later as regards existing models. I already walked August 2, 2027, as a grace for the already-placed. I am putting the press release next to that walk so a grocery line cannot catch me inventing a second clock. Two clocks can share a Code. Sharing is a calendar.

A later Commission page said the Commission and the AI Board had confirmed the Code as an adequate voluntary tool, and that providers who sign can show they comply by adhering, which would reduce administrative burden and give more legal certainty than other methods. Nelson Mullins, walking the same July, said conforming creates a rebuttable presumption of compliance. Recital weather in the NicFab walk of the 2026 omnibus still said codes have limited legal effect and do not confer a presumption of conformity. I am putting three mouths in one room. I will not pick a winner. I will say a Code can be called a presumption in a firm walk and a non-presumption in a recital, and that both can share a year with an implementing-act power, and that sharing is why Sid's counsel still bills the afternoon.

Yates wrote 13 experts / 1000 stakeholders / presumption vs no presumption and boxed vs. He said versus is how amateurs become novelists. I said I would not novelist. He dated the pad. The cutter waited the way a cutter waits when it has already eaten the coupon.

Sid taped the July 10 release to the landlord's copier. The tape said do not invent in Kit's hand. He asked whether signing would make the annex cheaper. I said cheaper is a grocery word. He said then why the invitation. I said invitations are a press release. He made the coffee that has one button and a grudge. The tray did not jam that afternoon. I did not take that as a sign. Signs are brochures.

Cosima asked if a Code was a password. I said it was a voluntary tool, in one mouth, and a presumption, in another, and a limited effect, in a third. She said three mouths are a mess. I said three mouths are a chapter. She peeled a sticker that had been on the release. The adhesive left a ghost over adhere. She put the ghost in the bowl anyway.

I sat, while I still had a badge, in a meeting whose title was code hygiene. Someone said we should "sign first and look serious." I said we should not sign a tool we had not read. Legal said we should take sign offline. We shipped a sentence about collaborative compliance. Collaborative is a brochure that shares a noun with a thousand stakeholders.

The Signatory Taskforce, in the digital-strategy walk, is chaired by the AI Office. A Vademecum holds rules of procedure and a list of members. I will not reprint the Vademecum as a kit. I will say a taskforce is a kitchen, and that a kitchen can share a chair with the Office that enforces, and that sharing is the exhibit I can hold without inventing a plot.

Hoyt sells keys in a booth that still has a grinder. I had a spare made because a policy shop had changed a lock and then changed it back. He asked if I was locked out. I said I was between a code and a journal. He said keys are between. I said a code still wants a spare. He dated the receipt.

GPAI models placed on the market before August 2, 2025, in the Mayer Brown walk, have until August 2, 2027, to comply with the relevant provisions. I am putting that date here so a grocery line cannot call the omnibus a holiday for the large. A grace for the already-placed is a costume. A costume can be honest and still be a line item Sid cannot staff.

Bec sells buttons in a jar that still has a lid. I bought two I did not need because a coat I wear to hearings had lost a pair. She asked if I was mending. I said I was between a grace and a journal. She said buttons are between. I said a grace still wants a coat that closes. She dated the receipt.