EU AI Act transparency deadline nears for providers and deployers

Most transparency obligations under Article 50 of the EU AI Act become applicable on 2 August 2026, requiring providers and deployers of AI systems used in the EU to review disclosures, notices and content-labelling practices. The European Commission has issued draft Guidelines expected to be finalised before the deadline, alongside a voluntary Code of Practice on Transparency of AI-Generated Content.

A Digital Omnibus on AI change gives providers more time for Article 50(2), moving its deadline to 2 December 2026 for AI systems that have been placed on the market before 2 August 2026. That provision requires providers of systems generating or manipulating synthetic audio, image, video or text content to mark outputs in a machine-readable format and make them detectable as artificially generated or manipulated.

Providers of AI systems intended to interact directly with people must inform users they are interacting with AI unless that fact is obvious or a law enforcement exemption applies. Deployers must notify individuals when biometric categorisation or emotion recognition systems process biometric data, disclose deep fakes, and identify certain AI-generated public interest text unless human review, editorial control or editorial responsibility applies.

All required transparency information under Article 50(1) to (4) must be clear, distinguishable, accessible and provided no later than the first interaction or exposure. Non-compliance may lead to administrative fines of up to €15 million or up to 3% of total worldwide annual turnover, whichever is higher.