The transparency obligations in Article 50 of Regulation (EU) 2024/1689 apply from 2 August 2026. The European Commission published guidelines in July 2026 clarifying which provisions take effect on that date and which benefit from extended deadlines introduced by the Digital Omnibus on AI. The 2 August 2026 date marks the third wave of AI Act obligations, following the prohibition of unacceptable-risk AI practices on 2 February 2025 and rules for general-purpose AI models on 2 August 2025.
Article 50(1) requires providers of AI systems that interact directly with natural persons to inform those persons they are dealing with an AI system, unless this is obvious from context. Article 50(4) requires deployers of AI systems that generate or manipulate images, audio, or video constituting a deepfake to disclose that the content is artificially generated or manipulated. Article 50(2), requiring machine-readable marking of AI-generated content, applies from 2 December 2026 for systems placed on the market before 2 August 2026, under a transitional arrangement introduced by the Digital Omnibus. Non-compliance with Article 50 carries fines of up to 15 million euros or 3% of global annual turnover, whichever is higher.
Providers of chatbots, virtual assistants, voice agents, and other human-facing AI systems must deploy Article 50(1) disclosure mechanisms before 2 August 2026. Media producers, advertisers, and social platforms that use AI to generate synthetic audio, images, or video must label deepfake content under Article 50(4) from the same date. Image and video generation platforms benefit from the Article 50(2) transitional window where systems entered the market before 2 August 2026. Each EU Member State's designated market surveillance authority takes primary enforcement responsibility for Article 50 violations in its jurisdiction.
The Digital Omnibus on AI introduced the four-month transitional window for Article 50(2) machine-readable marking for legacy systems. It is open whether the window applies to systems that receive substantive updates after 2 August 2026, and the Commission guidelines do not resolve this. Penalties for Article 50 violations sit below the maximum fines for prohibited AI practices (35 million euros or 7% of turnover) but above base administrative sanctions. National supervisory authorities may issue additional national-law penalties where implementing legislation permits.
Licentium advises AI providers and deployers on Article 50 compliance design, disclosure language, and interaction with national enforcement authorities across EU jurisdictions. Contact us to discuss transparency obligation scope, deepfake disclosure policy, or AI content marking strategy. Work we undertake includes Article 50 compliance audits, disclosure mechanism design, deepfake labelling policy drafting, GPAI model watermarking strategy, and cross-border compliance programme coordination.