On 20 July 2026, the European Commission published guidelines to assist providers and deployers of certain AI systems in meeting the transparency obligations under Article 50 of the EU Artificial Intelligence Act, Regulation (EU) 2024/1689. The guidelines are final and cover obligations that become enforceable from 2 August 2026, the date the Act's core application provisions take effect. The Commission also ran a targeted consultation on the draft guidelines, with feedback due by 23 July 2026, before publishing the finalised version.
Article 50 of the AI Act imposes obligations in two categories. First, providers of AI systems designed to interact directly with natural persons must inform those persons, before or at the start of each interaction, that they are communicating with an AI system. Second, providers and deployers using AI to generate synthetic audio, image, video, or text must ensure the output carries machine-readable disclosure markers before distribution; an exception applies to content that has undergone human editorial review and has been verified by an authorised person. Article 101 of the Act sets penalties for infringement at up to EUR 15 million or 3% of total worldwide annual turnover, whichever is higher.
Customer-service chatbot operators, AI voice-agent providers, and automated text-generation services must build disclosure interfaces notifying users of AI-system interaction before or at the start of each session. Content producers using generative AI for synthetic video, audio, or images must apply machine-readable technical markers before publication; broadcasters and news publishers relying on AI for text generation must assess whether the human editorial review exception applies to their output pipelines. Providers whose systems entered the market before 2 August 2026 have an extended compliance window to 2 December 2026 for content-labelling requirements only.
The Digital Omnibus, provisionally agreed by EU institutions on 7 May 2026, postpones obligations for Annex III high-risk AI systems from 2 August 2026 to 2 December 2027, separating the high-risk tier from the Article 50 transparency deadline. The Council gave final approval to the Digital Omnibus on 29 June 2026. The Commission is also publishing a Code of Practice on Transparency of AI-Generated Content developed by independent experts; the final version is expected after the consultation period closes. Each EU member state must designate at least one national AI regulatory sandbox by 2 August 2026.
Licentium advises technology companies, AI product deployers, and regulated firms on EU AI Act compliance, including Article 50 disclosure design, gap analyses, and provider and deployer obligation mapping. We assist with readiness assessments ahead of the August deadline and cross-jurisdictional compliance strategies. Contact us to discuss your obligations under the Act. Work we undertake includes AI Act obligation mapping, Article 50 disclosure notice design, high-risk AI classification, Digital Omnibus amendment analysis, and general-purpose AI model compliance.