EU AI Act Article 50 deadline: what applies now in 2026

Article 50 is already in application

The European Commission states that Article 50 applies from 2 August 2026. Provider and deployer transparency work should therefore be managed as a current operational requirement, not a future roadmap item.

The Article covers several distinct scenarios, including direct interaction with AI, machine-readable marking of generated or manipulated output, emotion recognition and biometric categorisation notices, deepfake disclosure and specified public-interest text disclosure.

The limited 2 December 2026 transition

The Commission's official questions and answers describe a limited grace period for AI systems placed on the market before 2 August 2026, and only for the marking and detection obligation in Article 50(2). Providers of those systems must meet that obligation from 2 December 2026.

This should not be presented as:

• a four-month delay for every Article 50 duty;
• permission to postpone chatbot interaction disclosure;
• a general exemption for small companies;
• a reason to stop visible deepfake or public-interest text disclosure work;
• proof that a specific legacy system meets the transition conditions.

Content generated before 2 August 2026 does not have to be labelled retroactively according to the Commission FAQ, although voluntary labelling is encouraged where possible.

What to do now

First week

Inventory directly interactive AI systems, generated-content pipelines, synthetic media publication, public-interest text workflows, emotion recognition and biometric categorisation uses. Assign a provider or deployer role per system and use case.

Second week

Deploy clear interaction notices and visible labels for the use cases already identified. Capture production evidence and accessibility results rather than stopping at draft wording.

Third week

Test machine-readable marking across every export format and transformation path. If relying on the limited transition, record when the system was placed on the market and obtain qualified review of the conditions.

Fourth week

Create ownership, change triggers, review dates and incident handling. Link each control to the current Commission guidelines, Code of Practice and Article text.

The Code of Practice

The Code of Practice on Transparency of AI-generated Content is voluntary, while the underlying Article 50 duties are legal obligations. The Commission and AI Board have assessed the Code as an adequate voluntary tool for demonstrating compliance with the marking and labelling obligations it addresses. Organisations using another approach should be ready to demonstrate why their measures are equivalently adequate.

Avoid deadline-only compliance

A notice deployed once can become stale after a redesign. A content credential can be stripped by a new export path. A human-review process can lose its responsible editor. Treat Article 50 as a maintained product control with tests, evidence and ownership.

Use the Article 50 readiness checker to map the current facts, then create versioned implementation tasks for every identified control.