On 10 June 2026, the European Commission published the Code of Practice on Marking and Labelling of AI-Generated Content. The Code supports compliance with Article 50(2) and Article 50(4) of Regulation (EU) 2024/1689, the EU AI Act. Adherence is voluntary, but the Code establishes the practical compliance benchmark against which providers and deployers of generative AI systems will be assessed when meeting Article 50 obligations from 2 August 2026.
Article 50(2) of Regulation (EU) 2024/1689 requires providers of generative AI systems to mark outputs, including audio, image, video, and text, in a machine-readable format detectable as artificially generated or manipulated. Article 50(4) requires deployers to label deepfakes and AI-generated text published to inform the public on matters of public interest. The Code specifies technical marking standards aligned with the C2PA (Coalition for Content Provenance and Authenticity) specification. Providers of generative AI systems placed on the market before 2 August 2026 have until 2 December 2026 to implement marking, under the grace period established by the AI Omnibus adopted on 29 June 2026. Systems entering the market on or after 2 August 2026 must mark from placement.
Providers of generative AI systems, including large language model developers, image generation platforms, video synthesis tools, and audio generation services, must embed machine-readable metadata into outputs and provide detection mechanisms. Deployers using generative AI to produce text on matters of public interest, including news services, government communication platforms, and public information systems, must label such content visibly. Generative AI systems producing deepfakes must carry both machine-readable marks and a disclosure visible to end users.
The Code does not impose marking obligations on open-source generative AI systems unless their providers have commercialised the system or retain meaningful control over outputs in deployment. Signatories to the Code accept monitoring and auditing obligations under the Code's governance structure. Open questions include enforcement mechanisms against non-signatories and the interaction between C2PA alignment requirements and media processing pipelines that strip metadata from content before distribution.
We may advise AI system providers and deployers on Article 50 compliance and the marking and labelling obligations under the EU Code of Practice. We have a partner network covering EU AI Act implementation and technical standards advisory. Contact us to assess your content marking infrastructure ahead of the 2 August 2026 compliance date. Work we undertake includes EU AI Act transparency obligation implementation, AI content marking technical review, GPAI code of practice compliance, AI governance policy design, and regulatory risk assessment.
Source: European Commission, Code of Practice on Marking and Labelling of AI-Generated Content, 10 June 2026