The Digital Omnibus moved the high-risk deadlines to December 2027 and August 2028. It did not move Article 50. Since 2 August 2026, an AI system that interacts with a person — or publishes content — has to say so, in a way a human can perceive without a detection tool. Up to €15 million or 3% of worldwide turnover.
Most organisations are in scope, and most do not know it — because the AI arrived as a feature of software nobody thinks of as AI. EU AI Act Navigator is an iPhone app that finds it, classifies it honestly, maps what you owe and by when, and hands you the registry as a document. Everything stays on the device.
Why now
The Digital Omnibus on AI was endorsed by the European Parliament on 16 June 2026 (423–57) and given final Council approval on 29 June 2026. It changed the dates everyone had planned around. Three corrections do most of the work.
Deferred. Standalone Annex III systems now apply from 2 December 2027; AI embedded as a safety component in products under Annex I harmonisation legislation from 2 August 2028. Important, but no longer the urgent thing.
It was not. Only Art. 50(2), the machine-readable marking of generative output, moved — to 2 December 2026. Art. 50(1), 50(3) and 50(4) have applied since 2 August 2026 and carry a penalty tier three times Article 4’s.
Softened. Article 4 now requires organisations to support the development of AI literacy — an obligation of effort, not of result. Still enforceable since 2 August 2026, up to €7.5M / 1%, and the evidence should be role-specific and logged per learner.
The app
The information you need is not sitting in a form waiting to be filled in. It is in the heads of the people you are sitting opposite. So the capture happens in the room, in a conversation — and the desk work happens afterwards, in the exported documents.
The app asks the follow-up questions: is this provider or deployer, does it talk to a person, is a feature switched off today that would escalate it. Capture by speaking, by photographing a vendor list or a settings screen, or by pasting a SaaS export — a system record in twenty seconds.
Four tiers — prohibited, high, limited, minimal — plus the two states real registries actually need: conditional (“minimal today, high risk the moment the HR AI feature is enabled”) and insufficient information, which opens an investigation task instead of guessing.
Per system and per role, mapped to the post-Omnibus dates. Article 50 is surfaced first, because it is the one that is live now, was not deferred, and catches the widest population. The timeline is shipped as data, so a change in the law is a content update.
The AI system registry, the obligation map, the prioritised action plan and the evidence pack — generated on the device as .docx and .xlsx, out through the iOS share sheet. The deliverable is a document a person hands to another person.
Every classification is a recommendation with its reasoning shown, always editable, and attributed to the human who accepted it. Each entry carries risk class, rationale, required actions, scope, and the escalation trigger that would move it up a tier.
A registry is only accurate on the day it is written. The 2 December 2026 and 2 December 2027 dates come back as scheduled reviews, and changing a system’s facts re-classifies it immediately.
Confidentiality
An inventory of the AI systems an organisation uses is a map of its internal estate and its unmitigated legal exposure. Handing that to a cloud compliance vendor is a real hesitation — and for a consultant holding someone else’s estate, often a blocker. So use it with no account at all and nothing ever leaves the device; or turn on sync and your assessment is encrypted on your iPhone first, with a key derived from your passphrase that we never receive. We store a blob we have no way to open.
Pricing
Enterprise AI governance platforms start in the tens of thousands per year and require a sales call. This is the tool for everyone below that line.
Requires iOS 26 or later. Voice capture uses Apple’s on-device speech recognition; AI-assisted prefill additionally needs a device with Apple Intelligence enabled (iPhone 15 Pro or later). Without them, every feature remains available by typing and tapping.