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From 2 August 2026, anyone using AI professionally in the EU market to generate or manipulate audio, video, images, and, in some cases, text must disclose it.
On 2 August 2026, the transparency obligations introduced under Article 50 of the EU AI Act started to apply to AI providers and deployers. The Act has been in force since 1 August 2024, with its obligations phased in gradually since then, and this marks one of the last major milestones in that rollout.
Who does it apply to?
The obligations apply to both providers (those who develop or place generative AI systems on the market) and deployers (those who use AI systems under their own authority for professional purposes). This includes providers and deployers outside the EU whose AI system's output is used within the EU.
What are the obligations?
In a clear and distinguishable manner and at the latest at the time of the first interaction or exposure:
providers must:
- inform people when they are interacting directly with an AI system, unless it is obvious; and
- mark AI-generated outputs in an effective, reliable, machine-readable format so that they are detectable and verifiable as AI-generated or manipulated, unless the AI system performs an assistive function for standard editing and does not substantially alter the input data or its semantics. Providers of systems that were already on the market before 2 August 2026 have until 2 December 2026 to comply with this particular obligation.
deployers must:
- label content that resembles existing people, entities, or events that have been falsely made to appear authentic or truthful (deepfakes), but this need only be disclosed in a way that does not hamper the display or enjoyment of the work where the content forms part of an evidently artistic, creative, satirical, fictional, or analogous work;
- label any AI-generated or manipulated text that is published specifically to inform the public on matters of public interest (such as politics, public health, or the administration of justice), unless that text has undergone human review and a person holds editorial control (text generated for other purposes, or not published with that public-interest aim, falls outside this particular labelling duty); and
- inform people exposed to any emotion recognition system or biometric categorisation system.
The European Commission recently adopted Guidelines on transparency obligations for providers and deployers of AI systems and published a Code of Practice on Transparency of AI-generated Content. The Code provides a framework for compliance with the marking and labelling obligations, including a set of icons for labelling AI-generated content. Signing the Code is voluntary, but non-compliance with the Act’s transparency obligations could result in fines of up to €15m or 3% of global turnover, whichever is higher.
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