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ARTICLE · 26 NOVEMBER 2025

Europe's Digital Rulebook Is Being Rewritten

William Fry LLP
William Fry LLP
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William Fry LLP

William Fry LLP

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The European Commission has released its Digital Omnibus Package, a reform that overhauls significant parts of the EU's digital regulatory framework.

IrelandTechnology
Barry Scannell
Barry Scannell
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The European Commission has released its Digital Omnibus Package, a reform that overhauls significant parts of the EU's digital regulatory framework.

It is presented as a simplification, introducing important changes across data law, cybersecurity, digital identity and the Artificial Intelligence Act. The package promises efficiency and lower compliance costs, but it also injects new uncertainty into the EU's most ambitious technology law. Nowhere is that more visible than in the future of high-risk AI.

A Floating Start Date for High-Risk AI

The AI Act originally set a clear timetable: high-risk systems were due to fall under binding obligations in 2026 and 2027. The Omnibus breaks that certainty. The new rules will only apply once the Commission adopts a formal decision confirming that harmonised standards, common specifications and support tools are available. Annex III systems, covering areas such as employment, law enforcement and access to public services,

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