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: captures model identity, version, and parameters at every decision eventHigh-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: SHA-256 hash-chained ledger captures every event at the point of generationDeployers 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: policy-traced invariant evaluation creates continuous documented risk managementAI 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: contemporaneous capture produces the disclosure documentation record at the moment of generationFull 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: builds the evidence record now so December 2027 is a confirmation, not a scrambleFCA-regulated firms must evidence who owns AI-enabled processes, what controls apply, and how performance is monitored.
KairoNull: produces the evidence pack the FCA expects to see, on demandOrganisations making automated decisions with legal effects must document the logic, significance, and envisaged consequences.
KairoNull: every record includes the governing policy, rationale, and outcomeQuick 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.
KairoNull deploys in minutes. No architectural changes. No model lock-in.