Check the connection to the European Union
The European Commission explains that the regulation can cover actors outside the EU when they place systems or models on the European market or put systems into service in the Union. A Canadian company should neither assume exemption nor presume that every activity is covered.
Use the updated timeline
The Commission states that the AI Omnibus entered into force on July 27, 2026. Its official notice moves application of the Annex III high-risk system rules to December 2, 2027, and rules for high-risk AI embedded in Annex I products to August 2, 2028. These extensions should not be read as a postponement of all obligations.
Assess each use case
Our recommendation is to inventory systems, purposes, users and markets. Then identify your role: provider, deployer or another actor in the chain. A recruitment screening system may be classified differently from a writing assistant.
Have legal counsel validate scope and deadlines against the applicable texts. Keep supplier information and classification decisions. A list of AI tools without their actual uses is insufficient to establish obligations.
Sources and features may change. Check the current version when planning your project. This article provides general guidance and does not replace legal analysis of your situation.
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