Article 50 of Regulation (EU) 2024/1689 (the EU AI Act) becomes applicable on 2 August 2026. The obligations are at the final rule stage, fixed in binding EU law. Four categories of transparency duty apply to providers and deployers of AI systems placed on the EU market. AI systems placed on the EU market before 2 August 2026 have until 2 December 2026 to comply with the machine-readable marking obligation in Article 50(2).
Article 50(1) requires providers of AI systems designed to interact with natural persons to ensure those systems disclose they are AI, unless this is evident from context. Article 50(2) requires providers of general-purpose AI systems capable of generating synthetic audio, video, image, or text to implement machine-readable marking of that content as AI-generated. Article 50(3) requires deployers using AI systems for emotion recognition or biometric categorisation to notify persons subject to those systems. Article 50(4) requires deployers generating or manipulating content constituting a deep fake, or AI-generated audio or video on matters of public interest, to disclose its artificial origin.
Foundation model providers, including large language model vendors, image synthesis platforms, and voice synthesis providers, must implement technical marking solutions under Article 50(2) and disclosure mechanisms under Article 50(1) where models face users directly. Consumer application operators deploying chatbots and virtual agents must prominently inform users they are interacting with an AI system. Media operators and synthetic content distributors producing deep fakes or AI-generated political and news content face mandatory disclosure obligations under Article 50(4). Operators of biometric data processing and emotion recognition systems must notify affected individuals under Article 50(3).
The European Commission published draft implementation guidelines on 8 May 2026; a public consultation on those guidelines closed on 3 June 2026 and the Commission has not yet published a final version. On 10 June 2026, the Commission published the final voluntary Code of Practice on Transparency of AI-Generated Content, which providers and deployers may use to demonstrate compliance with Articles 50(2) and 50(4). The Article 50(2) transitional period to 2 December 2026 applies only to systems placed on the EU market before 2 August 2026; systems entering the market on or after that date must comply immediately.
We advise AI system providers and deployers on EU AI Act compliance, including Article 50 transparency obligations and Code of Practice adoption. Work we undertake includes AI Act applicability assessments, Article 50 disclosure programme design, Code of Practice alignment reviews, technical implementation guidance for machine-readable marking, and regulatory engagement with national market surveillance authorities across EU member states.
Source: European Commission, Code of Practice on Transparency of AI-Generated Content, 10 June 2026