AI transparency: August duties and December transition
Article 50 applies from 2 August 2026. The December transition covers certain providers, rather than every transparency obligation.
Contents
Article 50 transparency obligations apply from 2 August 2026. The transition to 2 December 2026 is narrower: Article 111(4) covers providers of synthetic-content systems placed on the market before 2 August 2026 and their Article 50(2) obligations. It does not postpone every disclosure duty.
Machine-readable marking
Article 50(2) requires generative-system providers to make outputs machine-readable and detectable as artificially generated or manipulated. The technical solution must account for feasibility, content type, implementation costs and the generally acknowledged state of the art. This does not mean every organisation must use one particular watermark for every image.
Information for people
A provider of a system interacting directly with people must ensure they know they are interacting with AI, unless that is obvious from the context. Deployers of deepfake content must disclose its artificial origin or manipulation. Deployers of emotion recognition or biometric categorisation must inform the affected people. The information must be clear, distinguishable and accessible, no later than the first interaction or exposure.
Text generated to inform the public on matters of public interest has a separate rule. Article 50(4) provides an exception where human review or editorial control takes place and a person or legal entity holds editorial responsibility. A format check alone does not establish that condition.
Checking an implementation
Our proposed review method separates the provider’s technical marking from the notice a recipient sees. For a chatbot, record the first-contact screen and test the notice’s accessibility. For generated media, retain the original file, inspect available marking and check whether export or further processing removes it. Those checks create evidence for an assessment; they are not a universal compliance certificate.
The original report overstated the December transition and mixed provider and deployer roles. This revision distinguishes them explicitly.
Correction and update, 12 October 2026: The original report confused some dates and overstated legal obligations. This version follows the current consolidated regulation and the primary materials linked below. The original publication date is retained.
Sources: