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The EU AI Act has reached another major compliance milestone. From 2 August 2026, transparency obligations apply across the EU, requiring organisations to be more open about when and how they use AI.
For many businesses, these obligations will affect customer-facing AI tools and digital platforms including chatbots and marketing content generators. Organisations should consider developing product and use case intake processes into their internal governance and procurement processes to prepare for these new obligations as regulators are increasingly focused on transparency as a core compliance principle.
What should organisations consider?
Organisations should not assume that AI deployment can remain invisible to users. They should audit the systems and tools used to determine whether they:
- deploy AI chatbots or virtual assistants and ensure that users are clearly informed when they are interacting with an AI system rather than a human; and
- generate or manipulate content using AI, including text, images, audio or video, and whether the transparency requirements apply to such content.
It is essential for organisations to have governance processes in place to:
- identify where AI systems are being deployed or where AI-generated content is being shared so that appropriate transparency measures are implemented; and
- maintain records and controls demonstrating compliance with the AI Act’s transparency requirements.
For many organisations, the key challenge will be mapping existing AI use cases and ensuring that appropriate disclosures are embedded into products, services and customer journeys.
Increased regulatory focus in Ireland
The new transparency obligations come shortly after the enactment of Ireland’s Regulation of Artificial Intelligence Act, which establishes the AI Office of Ireland and the national enforcement framework for the AI Act. Ireland’s regulatory landscape for AI is therefore rapidly taking shape, with businesses now needing to consider both EU-level requirements and domestic supervisory arrangements.
At the same time, the AI Digital Omnibus Regulation reflects a broader EU policy focus on simplifying aspects of digital regulation while maintaining accountability and trust in AI systems. Notwithstanding the delayed implementation of certain obligations, organisations should not delay compliance efforts in respect of obligations that are already in force.
Next steps
The practical message for businesses is clear: identify where AI is being used, assess whether the Article 50 transparency obligations apply, and implement appropriate transparency measures now. Organisations that take a proactive approach will be better placed to manage regulatory scrutiny while building trust in their use of AI.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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