Digital Omnibus
Important compliance deadlines are being extended
The EU has officially adopted the Digital Omnibus Regulation on AI (Regulation (EU) 2026/1744). It was published in the Official Journal of the European Union on July 24, 2026, and entered into force three days later. The goal of the regulation is to make the implementation of the AI Act more practical for companies without compromising the fundamental requirements for safety, transparency, and governance. In particular, it focuses on the extended deadlines for the operation of so-called high-risk AI systems.
Digital Omnibus: Good News for CFOs and Finance Departments
For in-house finance professionals, this is generally good news. Many companies saw this as a challenge, as the originally planned deadlines for AI Act . Nevertheless, it would be a mistake to view the Digital Omnibus as a general relaxation of the AIRegulation: The Essentials governanceand transparency requirements remain unaffected.
Why was the Digital Omnibus introduced?
The European Commission is thus responding to extensive feedback from the business community. In addition to unclear implementation guidelines, many companies also criticized the lack of technical standards, duplicate regulations, high documentation burdens, and uncertainties regarding the classification of AI systems.
Accordingly, the regulation aims to simplify the European legal framework for digital technologies while strengthening the competitiveness of European companies. At the same time, the multitude of regulations targeting AI should not be perceived as an obstacle to investment for companies.
Transparency requirements remain in effect
While some high-risk requirements have been postponed, other regulations remain in effect.
In particular, obligations remain in effect for:
- Transparency in AI Systems
- Labeling AI-Generated Content
- Requirements for General-Purpose AI Models (GPAI)
- Documentation, Competency, and Verification Requirements
Companies therefore cannot delay the implementation of governance processes.
The EU AI Office Is Being Given More Powers
The Digital Omnibus significantly strengthens the role of the European AI Office. Specifically, the agency is granted additional powers in the following areas:
- Market Surveillance
- Enforcement of the AI Act
- Regulation of Major AI Platforms
- Supervision of Certain GPAI Systems
For financial organizations, this means that AI compliance could become just as important in the future as data protection or information security.
How does this affect finance departments?
AI regulation does not primarily concern IT issues, but has significant practical implications for processes in finance and accounting. AI applications are particularly relevant in:
- Forecasting and Planning
- Cash Management
- Creditworthiness Analyses
- Fraud Detection
- Reporting and Narrative Reporting
- SAP Joule and other AI assistants
- Agentic AI Applications in the ERP Environment
The key question going forward is: Which decisions are prepared or influenced by AI, and how can their traceability be ensured?
Evaluating SAP AI Applications
SAP is continuously expanding its solutions to include AI features such as SAP Joule or specialized agents. The majority of finance applications are likely to continue to be considered low or limited risk. However, this always depends on the specific use case—not on the product label. Nevertheless, CFOs should work with IT and compliance to assess:
- Which AI components are used?
- What data is fed into the models?
- What decisions does AI influence?
- What documentation will need to be submitted in the future?
This is especially true for automated decision-making processes in controlling and reporting.
However, if Joule is used in areas that fall under the high-risk categories listed in Annex III of the EU AI Act, its use may be considered high-risk AI. Examples include:
- Candidate Selection
- Recruiting Rankings
- Performance Reviews
- Career or Promotion Recommendations
Especially for HR roles in SAP SuccessFactors, relevant high-risk scenarios are discussed.
A German Special Feature: the KI-MIG
The AI-MIG (Act on Market Surveillance and Innovation Promotion for Artificial Intelligence) is the German July 29, 2026 German accompanying law for the national implementation of the European AI Regulation (AI Act). It regulates the regulatory oversight structure, designates competent authorities, establishes incentives for innovation, and designates the Federal Network Agency as the central coordinating body. The Federal Network Agency is designated as the highest enforcement authority. For AI systems in the financial sector, BaFin has been designated and plans to begin active oversight starting in August 2026. The AI-MIG itself provides for fines of up to €50,000 per violation for certain breaches of obligations to cooperate, provide information, or tolerate certain practices. Violations of prohibited AI practices, however, can be penalized under the EU AI Act with fines of up to 35 million EUR or 7% of global annual revenue; lower fines apply to small and medium-sized enterprises.
Conclusion: Make Good Use of the Grace Period
The EU Digital Omnibus gives companies more time to prepare in a structured manner—in particular, the postponement of the high-risk rules reduces short-term implementation pressure.
For CFOs, however, this does not mean that the company-wide effort to address AI compliance can be postponed. Quite the opposite is true: The extra time should be used to strengthen governance structures, documentation processes, and control mechanisms.
The key question is no longer whether AI will be regulated, but how well companies are already able to manage, document, and monitor their AI applications today.
Finance departments, in particular, should seize this opportunity to take on a leading role. As a rule, they already possess the necessary expertise in the areas of governance, risk management, compliance, and internal control systems. AI governance in the future is therefore likely to be much more closely tied to the CFO than many people still assume today.
Written by
Prof. Dr. Martin Wünsch is an expert in financial reporting and SAP S/4Hana Finance Consulting. He is familiar with this field from various perspectives, e.g., Big4-Audit, Corporate Functions, or Management Consulting. He holds a chair in Business Administration, in particular in Int, Accounting & Controlling, at the FOM University of Applied Sciences Düsseldorf and regularly publishes on current topics in financial reporting.