Article 50 of Regulation (EU) 2024/1689 (the EU AI Act) enters into application on 2 August 2026, marking the transparency phase of the Act's phased roll-in. The EU AI Act entered into force on 1 August 2024. Prohibited AI practices took effect on 2 February 2025. General-purpose AI model obligations entered application on 2 August 2025. Article 50, alongside most high-risk AI system requirements, takes effect on 2 August 2026.
Article 50 imposes four disclosure duties. First, providers of AI systems designed to interact directly with people must inform users they are communicating with AI, unless the AI nature is evident from context. Second, providers of generative AI systems must implement machine-readable marks in outputs enabling detection of synthetic content, referencing technical standards under Article 50(7). Third, deployers using biometric categorisation, emotion recognition, or deepfake AI systems must disclose that use to affected persons. Fourth, any person producing AI-generated content on matters of public interest must label that content as AI-generated or AI-manipulated.
The obligations reach providers of large language models, image generators, synthetic audio tools, and other generative AI systems placed on the EU market. Deployers using third-party AI in their products or services bear separate disclosure duties toward end users. Media operators, political advertisers, professional service firms producing AI-generated client-facing documents, and operators of customer-facing AI chatbots must each assess their Article 50 obligations. Machine-readable marks must be embedded in AI output pipelines from 2 August 2026.
Each EU member state designates a competent authority and market surveillance authority under Article 70 to enforce Article 50. Fines fall under the general AI Act penalty regime, reaching up to EUR 15 million or 3% of global annual turnover for relevant violations. The European Commission published a Code of Practice on marking and labelling of AI-generated content in 2026 to guide compliance, but adherence does not substitute for meeting the statutory requirements. GPAI model providers face additional transparency obligations under Article 53, which entered application on 2 August 2025.
Licentium advises providers and deployers of AI systems on EU AI Act compliance, covering Article 50 disclosure obligations, GPAI model governance, and national implementation requirements across EU jurisdictions. We maintain a partner network with EU regulatory counsel for AI Act conformity assessment and enforcement readiness. Work we undertake includes EU AI Act compliance gap analysis, technical disclosure programme design, GPAI model documentation, and multi-jurisdictional AI regulatory mapping.