The transparency obligations in Article 50 of Regulation (EU) 2024/1689 apply from 2 August 2026. This date was not altered by the AI Omnibus and remains fixed. The European Commission published finalised guidelines on the scope and application of Article 50 in July 2026 to support provider and deployer compliance.
Under Article 50(1), providers of AI systems that interact directly with natural persons must make the AI nature of the interaction clear, unless this is obvious from context. Article 50(2) requires providers of generative AI producing text, images, audio, or video to mark outputs in machine-readable format as artificially generated. Article 50(4) requires deployers producing deepfakes to label that content as artificially generated or manipulated.
Chatbot providers, generative image platforms, and AI video tools serving the EU market must implement Article 50 disclosure mechanisms by 2 August 2026. Deployers using AI in advertising, political content, or media production must label synthetic outputs. Non-compliant providers face administrative fines up to EUR 15 million or 3% of global annual turnover, whichever is higher.
A transitional provision applies to the machine-readable marking obligation in Article 50(2) for AI systems placed on the market before 2 August 2026. Providers of those pre-existing systems have until 2 December 2026 to achieve compliance with the marking requirement. The Code of Practice on AI-generated content, currently in development, will provide technical guidance on implementing marking and labelling.
Licentium advises providers and deployers on Article 50 compliance, including disclosure architecture and contractual obligations between AI system providers and deployers. We also advise on regulatory filings with national competent authorities and interaction with the EU AI Office. Work we undertake includes AI Act applicability assessments, Article 50 compliance programmes, GPAI model documentation, and representation before national AI market surveillance authorities.