From the journal

European Commission Issues AI Act Article 50 Transparency Guidelines Effective 2 August 2026

On 20 July 2026, the European Commission adopted guidelines clarifying transparency obligations for providers and deployers of AI systems under Article 50 of Regulation (EU) 2024/1689. The guidelines cover disclosure requirements for interactive AI systems and labelling of AI-generated content. Obligations apply from 2 August 2026; AI systems placed on the market before that date must comply with content-labelling requirements by 2 December 2026.

3 min read

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.

Source: European Commission, Guidelines on Transparency Obligations for Providers and Deployers of AI Systems under Article 50 of Regulation (EU) 2024/1689, 20 July 2026

AI Regulatory

More from the journal

See all

Hong Kong SFC and FSTB Conclude Consultation on Virtual Asset Advisory and Management Regimes, 26 May 2026

On 26 May 2026, Hong Kong's Securities and Futures Commission and Financial Services and the Treasury Bureau published consultation conclusions on proposed licensing regimes for virtual asset advisory and management service providers. The regimes apply the same business, same risks, same rules principle and align SFC licensing requirements with those for securities advisory and management businesses. A bill implementing the regimes is planned for introduction into the Legislative Council in 2026.

OCC Grants Circle Final Charter for First National Digital Currency Bank N.A., 9 July 2026

The Office of the Comptroller of the Currency granted final approval on 9 July 2026 for Circle Internet Group to establish First National Digital Currency Bank, N.A., operating as Circle National Trust. The bank opened 24 July 2026 under direct OCC oversight and will manage USDC reserves on a directed basis, act as collateral trustee for USDC holders, and provide digital asset custody services to Circle affiliates.

Manitoba Enacts Public Sector AI and Cybersecurity Governance Act June 2026

On 1 June 2026, Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act (S.M. 2026, c. 43), received Royal Assent in Manitoba, Canada. The Act mandates transparency, accountability structures, and cybersecurity incident reporting for public sector entities using AI systems. Substantive obligations take effect only through regulations yet to be made.