The Digital Omnibus on AI is a legislative package from the EU Commission introduced on November 19, 2025. Its goal is to adjust the EU AI Act regarding key effective dates and specific provisions. The proposal has been undergoing trilogue negotiations between the European Parliament, the Council, and the Commission since March 2026. A political agreement is targeted for the second trilogue on April 28, 2026 (Source: A&O Shearman, April 2026; Ropes & Gray, April 2026; OneTrust, April 2026; Mondaq, April 2026). Key developments in the negotiation process: The Council adopted its negotiating position on March 13, 2026. The European Parliament adopted its position on March 26, 2026, with 569 votes in favor, 45 against, and 23 abstentions, following the IMCO and LIBE committees' adoption of the joint report on March 18, 2026, by a vote of 101 to 9 with 8 abstentions (Source: European Parliament, press release March 26, 2026; nicfab.eu, March 27, 2026; European Parliament Legislative Train Schedule). Key changes under the current proposal: High-risk obligations under Annex III would be postponed from August 2, 2026, to December 2, 2027. High-risk obligations under Annex I (embedded in regulated products) would be postponed to August 2, 2028. Both institutions reject the original Commission trigger mechanism (postponement linked to the availability of harmonized standards) in favor of fixed dates.
For SAP customers with ongoing AI projects, the status of the trilogue as of April 2026 serves as a planning signal, but not an all-clear. Three aspects are operationally relevant: Watermarking deadline: November 2, 2026. The watermarking obligation under Article 50 (3)—requiring synthetic audio, image, video, and text content to be marked as AI-generated—applies from November 2, 2026, and is excluded from the postponement discussion. This date is relevant for SAP customers using Joule or other generative AI tools to create content for external communication (Source: Ropes & Gray, April 2026; A&O Shearman, April 2026). Transparency obligations (Article 50) remain active. The obligation to label chatbot interactions (users must know they are communicating with an AI) applies from August 2, 2026. This requirement remains unchanged across all negotiation stages. Planning signals for high-risk compliance. If the political agreement is reached on April 28, 2026, and the postponement to December 2, 2027, takes effect, companies will have additional time for conformity assessments and FRIA preparations. This does not change the fact that the lead time for a conformity assessment is three to six months.
The watermarking obligation is the new operational task for Q2-Q3 2026: Affected scenarios for SAP customers. Joule as a conversational assistant falls under the chatbot transparency obligation (Article 50, effective August 2, 2026). Joule-generated reports or documents communicated externally fall under the watermarking obligation (Article 50 (3), effective November 2, 2026). Internal use of Joule for analysis or summaries without external communication may not be affected, but the line between internal and external is not always clear-cut. Dual-track planning. Track A remains: Transparency obligations from August 2, 2026, and watermarking from November 2, 2026. Track B updated: If the political agreement is reached on April 28, the high-risk target date shifts to December 2, 2027. Track B continues; it is not on hold. Conservative classification until guidance is issued. Commission guidance under Article 6 is still missing. Conservative classification for borderline cases remains the recommended practice.
No political agreement on April 28. If the second trilogue on April 28, 2026, does not result in an agreement, the original deadline of August 2, 2026, for high-risk obligations remains in effect. Further trilogues would be necessary, which would make the timeline very tight. National implementation deviations. The national AI implementation act in Germany is currently being prepared. The final text is not yet available. Individual member states may implement stricter requirements. For DACH clients, this means: the EU framework sets the minimum, but national law may be more stringent. Publication and entry into force. Even with a political agreement on April 28, 2026, formal publication in the Official Journal of the EU and entry into force will take several more weeks. A postponement intended to take effect before August 2, 2026, requires a very rapid process.
Do not wait for the trilogue outcome. Regardless of the outcome of the second trilogue: transparency obligations (starting August 2, 2026) and watermarking (starting November 2, 2026) are treated as fixed. These tasks start now. High-risk preparation continues. Track B continues at the original pace. If the postponement occurs, the new date will be set as the target, not as a signal to pause. Start the AI inventory immediately. Regardless of the legislative outcome, the AI inventory is the first operational mandatory task. Without an inventory, there is no classification process; without classification, there is no reliable planning.
The Digital Omnibus trilogue aims for an agreement on April 28, 2026. A postponement of high-risk obligations to December 2, 2027, is likely. However: the watermarking deadline of November 2, 2026, is fixed, and transparency obligations for August 2, 2026, are fixed. Dual-track planning continues, and the AI inventory starts now.