EU AI Act in hospitals: what moved and what did not

"The AI Act got delayed." In hospitals we hear it a lot since the summer. It is only partly true. Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force on 27 July 2026. It moved two deadlines that matter for care. Several obligations stayed exactly where they were.

What moved

December 2027 for AI that triages emergency patients or decides on access to care.
August 2028 for AI inside medical devices that need a notified body under the MDR or IVDR.

What did not move

AI literacy for care and admin staff, in force since February 2025.
Transparency: since August 2026, patients must know when they deal with an AI system.
Marking of AI-generated content: the grace period ends on 2 December 2026.

Timeline of EU AI Act obligations for hospitals. In force: AI literacy (2 February 2025), patient transparency (2 August 2026). Next: marking of AI-generated content (2 December 2026). Deferred: high-risk AI for emergency triage and access to care (2 December 2027), AI in medical devices (2 August 2028). — The timeline as published on our LinkedIn page, 9 October 2026. Source: Regulation (EU) 2026/1744.

Not every AI tool is high-risk

Scheduling, documentation and back-office automation usually are not high-risk. They still fall under the rules above: staff who use them need AI literacy, patients who meet them need to know, and generated content needs marking.

Three questions to start with

In our hospital projects, readiness starts with three questions:

Which AI tools are already in use, from the ward to the back office?
Where does a care professional confirm before the AI acts?
Can you show afterwards what the system did, and why?

The first question is often the hardest. Tools arrive through suppliers, pilots and individual teams, and nobody holds the full list. That list is where readiness starts.

Key takeaways

Two healthcare deadlines moved: December 2027 (triage, access to care) and August 2028 (medical devices).
AI literacy and patient transparency already apply. Content marking follows on 2 December 2026.
Low-risk tools such as scheduling and documentation still fall under these rules.
Readiness starts with a list of the AI tools already in use.

Facts checked on 9 October 2026 against Regulation (EU) 2026/1744. This article is general information, not legal advice.

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