Quick Hits

• The European Union has provisionally agreed to delay the implementation of high-risk AI regulations in employment decisions until December 2, 2027.
• Subject to formal adoption, the agreement would delay the requirements for “high-risk” systems, which include those intended to be used to make decisions affecting employment terms, promotion, termination, task allocation, and monitoring or evaluating workers’ performance.
• Although the revised deadline is expected, employers may still want to prioritize preparing for compliance by the original deadline considering the scope of the EU AI Act’s requirements.

New Deadline Pending

On May 7, 2026, the European Parliament, Council of the European Union, and the European Commission reached a provisional agreement on a proposal, the Digital Omnibus on AI, to amend parts of the EU AI Act. On June 16, 2026, the European Parliament approved the provisional agreement, which now must be formally approved by the Council before it becomes law.

Notably, among the changes, the proposal would delay the application of the AI Act’s requirements for high-risk AI systems, which include those used in employment, until December 2, 2027.

Once the agreement is approved by the Council, the amendments would enter into force three days after publication in the Official Journal of the European Union. Publication is expected before August 2026.

For employers, the key point is that the delay is not a repeal. Employment-related AI remains...

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