What happened.
On 21 August 2026, the Spanish Artificial Intelligence Supervisory Agency (AESIA) announced the availability of its sixteen support guides for the EU Artificial Intelligence Act, presented as adapted to the changes introduced by the Digital Omnibus. The guides originate from the Spanish AI regulatory sandbox pilot and were first published in 2025; they are not new documents, but an update of the practical reference that companies and compliance teams were already using.
The detail that matters.
The adaptation is not uniform: fifteen of the sixteen documents now display version 2.0 with declared adaptation to the Omnibus; the sixteenth — the checklist user manual — remains at version 1.1. Anyone working with the full package needs to know which document is aligned with the current framework and which has not yet been revised.
Why it affects you.
If your company ran its compliance analysis against the 2025 guides, that analysis is built on superseded documents. The guides impose no new obligations — they do not replace the Regulation — but they are the practical standard the Spanish supervisory authority itself uses as a reference, and AESIA is already operating with inspectors and enforcement powers. Working from the old version is the easiest possible way to end up with a documentation gap.
What has not changed.
The high-risk timeline stays where the Omnibus left it: full obligations for high-risk systems point to 2027. But the obligations already in force — Article 50 transparency (chatbots, synthetic content, deepfakes), Article 4 AI literacy, the prohibitions — do not move, and the updated guides are precisely the tool for complying with them today.
What to do this week:
- Download the updated package (Spanish and English versions) and withdraw any 2025 copies circulating internally.
- Open a version-control log: record the fifteen v2.0 guides and flag the checklist manual (v1.1) as pending revision by AESIA.
- Review the gap analysis done against the earlier guides: check whether the Omnibus changes affect its conclusions, particularly on transparency and documentation.
- Do not mix up the guides: the guide on Article 13 (information for deployers of high-risk systems) does not cover Article 50 (transparency towards end users). They are different obligations, and complying with one does not discharge the other.
- Document the update: keeping a record that the company works from the current version is evidence of diligence in any inspection.
How we can help.
At Ferrer-Bonsoms Abogados we support technology companies and AI users in adapting to the AI Act: system inventory, gap analysis against the current guides, and a documented compliance plan.