EU AI disclosure rules can reach US businesses

The European Commission published guidelines on 20 July 2026 for transparency rules under the EU AI Act, with obligations applying on 2 August 2026. The rules can cover US businesses because the Act applies when AI output is used in the Union, regardless of whether the provider or deployer is located inside the EU.

The core requirements center on disclosure. Users must be told when they are interacting directly with an AI system unless that is already obvious to a reasonably well-informed person. Providers of generative AI must mark synthetic audio, image, video, or text in a machine-readable and detectable format where technically feasible. Deployers must disclose deepfakes, disclose AI-generated or AI-manipulated public-interest text unless it has human review and editorial responsibility, and inform people exposed to emotion-recognition or biometric-categorization systems.

Article 50 violations can bring fines of up to 15,000,000 EUR, or for a company, up to 3% of total worldwide annual turnover, whichever is higher. The European AI Office also released a voluntary Code of Practice on Transparency of AI-Generated Content on 10 June 2026, with the initial signing deadline set for 27 July 2026 at 18:00 CEST.

US companies are advised to review customer-facing chatbots, generated marketing media, AI-drafted public content, and any emotion or biometric tools, then add plain disclosures where a reasonable person may not know AI is involved.