Since 2 August 2026, Article 50 has imposed defined AI transparency obligations in the EU. Not every AI output receives the same marking, and exceptions differ by obligation.
Separate who informs whom
Provider duties concerning direct interaction and machine-readable marking differ from deployer duties for certain deepfakes, public-interest text and emotion or biometric systems. A vendor putting a hidden metadata marker into a file may not satisfy a deployer’s human-facing disclosure duty.
Find the applicable exception
Whether interaction is already obvious, a work is artistic or satirical, or a criminal-law exception applies depends on the relevant paragraph and safeguards. Do not use the existence of one exception to waive all Article 50 duties.
Two different 2026 dates
The Commission specifies that Article 50 applies from August 2, 2026, while a limited December 2, 2026 grace period applies to defined marking and detectability obligations for systems placed on the market earlier. It does not globally postpone every transparency duty.
Preserve metadata through workflow changes
Editing, compressing, screen-capturing or distributing media may remove machine-readable provenance. Test export formats and user-facing notices separately. Independent fact-checking remains necessary even when provenance is authentic.
Design for access, not checkbox theater
Human-facing disclosures should be clear, distinct and accessible. Test visually, using assistive technologies and for languages of affected audiences. Store evidence of the label that users actually see.
Make a duty map
For each feature, record provider/deployer role, exact Article 50 paragraph, content type, audience, exception, start date and implementation evidence. Specialist review is needed for edge cases and changing Commission guidance.
Dated first-party verification and limits
Article 50 must be read by paragraph and actor: a provider’s machine-readable marking obligation is different from a deployer’s notice to an audience. The Commission’s consolidated Article 50 reflects amendments as at 27 July 2026. A transition for certain pre-existing providers under paragraph 2 is not a blanket postponement of chatbot interaction notices or every deepfake disclosure.
Sources & Further Reading
- European Commission FAQ on Article 50 — European Commission.
- Consolidated EU AI Act, 27 July 2026 — EUR-Lex / European Union.
- Article 50 consolidated text (27 July 2026) — European Commission AI Act Service Desk.
- When does AI Act enforcement start? — European Commission AI Act Service Desk.
Jurisdiction/scope: European Union. This is educational information and does not constitute legal or other professional advice. No hands-on product test is claimed.