Article 50 of Regulation (EU) 2024/1689 entered general application on 2 August 2026. The European Commission's AI Office began monitoring compliance on that date, marking the shift from prospective obligation to active enforcement. The provision imposes four disclosure duties, split between AI system providers and deployers.
Article 50(1) obligates providers of AI systems designed for direct interaction with natural persons to make the system's artificial nature identifiable, unless that nature is obvious from context. Article 50(2) obligates providers of generative AI systems to mark synthetic audio, image, video, and text outputs with machine-readable signals enabling automated detection. Article 50(3) obligates deployers of emotion recognition and biometric categorization systems to notify persons exposed to those systems. Article 50(4) obligates deployers distributing AI-generated content on matters of public interest online, without human review or editorial control, to label that content as AI-generated.
AI system providers must embed machine-readable marks into generative outputs before placing systems on the EU market. Chatbot operators and virtual assistant providers must configure those systems to declare their artificial nature at the start of each user interaction. Deployers using AI emotion recognition in employment, insurance, or healthcare settings must notify affected individuals before or at the point of assessment. Online publishers and content distributors relying on AI to generate public interest text at scale, without human editorial review, must attach AI-generated labels to qualifying output.
A grace period applies to the Article 50(2) marking obligation. Providers of generative AI systems placed on the market before 2 August 2026 must comply with that marking requirement only from December 2026. No equivalent grace period covers the Article 50(3) notification duties for emotion recognition and biometric categorization systems. The Commission's voluntary Code of Practice on Marking and Labelling of AI-generated Content does not satisfy the Article 50(2) statutory requirement. Binding technical standards specifying required machine-readable marking formats have not yet been adopted.
Licentium advises providers and deployers on EU AI Act Article 50 compliance and broader AI regulatory requirements across the EU market. Work we undertake includes Article 50 obligation assessments, provider and deployer role classification, machine-readable marking strategy, AI Office engagement, and interaction with national market surveillance authorities.