Topic
Transparency and deepfakes
Start with Article 50 AI Act: explanation by paragraph, with the role split, the dates and examples.
The transparency obligations have applied since 2 August 2026, making them the first duties in this category that are genuinely enforceable. They affect almost every organisation running a chatbot or generating content with AI. Below is what is required, for whom, and which transition period is still running.
Official guidance on this topic
13- Guidelines on transparency obligations for providers and deployers of certain AI systems under Article 50 of the AI ActFinal guidelines (C(2026) 5054 final), adopted following consultation on the draft version of 8 May 2026. They clarify the scope, definitions and content of obligations for providers and deployers: designing systems so that people know they are communicating with AI, marking AI-generated or manipulated content in machine-readable form, informing people about deepfakes, about AI-generated text on matters of public concern without human editorial oversight, and about emotion recognition and biometric categorisation. Exceptions such as standard processing operations and artistic or satirical context are addressed. Separate paragraphs address the interplay with data protection law and refer to joint guidelines to be drawn up by the Commission and EDPB. Non-binding, but directive for how supervisors interpret Article 50. The obligations apply from 2 August 2026.PublishedGuidelinesEuropean Commission20 Jul 2026
- Code of Practice on Transparency of AI-generated ContentVoluntary code of practice in two sections: section 1 on marking and detectability of AI-generated or manipulated content by providers, section 2 on labelling deepfakes and AI-generated text by deployers. The code describes watermarks, metadata and provenance information and contains the EU icons for visible labels. Signature can be per section; the deadline for initial signatories was 27 July 2026 and as of end of July 2026 approximately 190 organisations were listed. Process: consultation September 2025, first draft 17 December 2025, second draft 3 March 2026, final 10 June 2026. The code helps demonstrate compliance with Article 50 but does not replace statutory obligations.PublishedCode of practiceEuropean Commission / AI Office10 Jun 2026
- EU icons for labelling AI-generated contentFreely available set of EU icons in SVG and PNG format that creators and deployers use to make AI involvement in content visible, in three variants: AI involvement, fully AI-generated and partially AI-modified. The icons form part of Section 2 of the Code of Practice on the transparency of AI-generated content and became available on 10 June 2026; the page was last updated on 6 August 2026. User research by the Commission shows that the basic icon performs better when displayed together with a text label. Use of the icons is voluntary; the labelling obligation under Article 50 is not.PublishedTemplateEuropean Commission / AI Office6 Aug 2026
- Transparency obligations under Article 50 of the AI Act - Questions and AnswersOfficial questions and answers on the guidelines to Article 50. The page addresses who is provider and who is deployer, when a system must disclose that the user is communicating with AI, what requirements apply to machine-readable marking of synthetic content, and how the discoverability of deepfakes and AI-generated text on matters of public concern must be handled. The exception for human editorial oversight, the way compliance can be demonstrated and enforcement are also covered. The page confirms that a limited transition period applies to systems placed on the market before 2 August 2026, exclusively for the marking and detection obligation of Article 50, paragraph 2, to which they are only required to comply from 2 December 2026. The date 24 July 2026 is the last-updated date.PublishedQ&AEuropean Commission, DG CONNECT24 Jul 2026
- Questions and answers on the Code of Practice for General-Purpose AIQ&A on the code of practice for general-purpose AI models. The Commission emphasises that the code is voluntary and creates no new obligations, but serves as a tool to comply with the existing obligations in the regulation. The code has three chapters: transparency and copyright for all general-purpose AI providers, and safety and security only for providers of the most advanced models with systemic risk. It also clarifies how the transparency rules for general-purpose AI models relate to the transparency obligations of Article 50 for AI systems. The date 20 July 2026 is the last updated date on the page.PublishedQ&AEuropean Commission, DG CONNECT20 Jul 2026
- EDPB Work Programme 2026-2027 (announcing joint guidelines on the interplay between the AI Act and the GDPR)The European Data Protection Board work programme 2026-2027, adopted on 11 February 2026, announces joint guidelines on the interplay between the AI Act and the GDPR. These guidelines do not yet exist; the Commission confirms in its Article 50 guidelines of 20 July 2026 that they are being prepared together with the European Data Protection Board. They are expected to address transparency, risk assessments, bias detection and accountability, with concrete examples.AnnouncedGuidelinesEDPB (European Data Protection Board)11 Feb 2026
- Guidance on generative AI and the GDPRThe first Dutch interpretation of the GDPR for the development and deployment of generative AI models, intended for organisations that build such models or are responsible for their use. The guidance addresses the legal basis for processing in detail and also works out further GDPR requirements for development and deployment. It builds on the earlier opinion from the Dutch Data Protection Authority on generative AI and refers to the obligations that the AI Act imposes on general-purpose AI model providers. The document is dated June 2026 internally and was published on 13 July 2026.PublishedGuidelinesDutch Data Protection Authority (AP)13 Jul 2026
- Transparency requirements for AI: what does this mean for you?Public explanation by the Dutch Data Protection Authority of the transparency rules that have applied since 2 August 2026, with a downloadable infographic. Four situations: AI systems such as chatbots must be recognisable, AI-generated content receives a digital marking, people are informed about emotion recognition and biometric categorisation, and deepfakes and unedited AI articles on matters of public concern receive a visible label. The Authority confirms that systems placed on the market before 2 August 2026 have four additional months for the marking obligation, namely until 2 December 2026. Living topic page, updated on 31 July 2026.PublishedQ&ADutch Data Protection Authority (AP)31 Jul 2026
- AI transparency requirements apply from 2 August: AP advises signing the code of practiceThe AP sets out the four transparency obligations with precise reference to Article 50, paragraphs 1 to 4, and advises providers and deployers of generative AI to sign the European code of practice on the transparency of AI-generated content. This code of practice was published by the European Commission on 10 June 2026 and contains freely usable EU icons with the labels AI, AI generated and AI modified. The Commission kept 27 July 2026 at 18:00 CEST as the cut-off for the list of initial signatories (22 July had been mentioned earlier); later signature remains possible. The DCA announces it will publish further guidance in the coming months.PublishedNational guidanceDutch Data Protection Authority (AP), Algorithm Coordination Directorate9 Jul 2026
- Supervision of AI takes shape: key role for the AP and the RDIResponse by the AP to the draft bill. The AP makes explicit which parts it will itself enforce: prohibited AI practices, transparency obligations such as the detectability of chatbots and deepfakes, and a large part of high-risk applications in work, education and government. The AP and RDI jointly provide coordination, knowledge-building and harmonisation, and will establish an AI regulatory sandbox from 2026 onwards. The AP stresses that parts of the Regulation already apply while the implementing legislation is not yet in force.PublishedNational guidanceDutch Data Protection Authority (AP), Algorithm Coordination Directorate20 Apr 2026
- Work agenda for coordinating AI and algorithm supervision 2026The work agenda in which the AP as coordinating algorithm supervisory authority sets out its activities for 2026, divided across five pillars: mapping risks, systemic supervision, cooperation, shared knowledge base and preparation for the AI Regulation. In substance, the AP focuses in 2026 on transparency and explainability, clear frameworks and standards, bias and fairness testing against discrimination, and AI literacy. On the same date, the AP published its 2025 review.PublishedNational guidanceDutch Data Protection Authority (AP), Algorithm Coordination Directorate26 Mar 2026
- Report AI & Algorithms Netherlands (RAN) - March 2026Sixth edition of the half-yearly report in which the AP analyses the risks and effects of AI and algorithms in the Netherlands via the AI Impact Barometer. Four of the nine indicators are now red, compared with two in the previous edition. The three main points are that AI in recruitment and selection is growing rapidly with significant risks, that transparency and explainability are falling short, and that preparation for the AI Regulation is lagging. The AP also signals that organisations are attempting to circumvent the rules or failing to comply with them.PublishedNational guidanceDutch Data Protection Authority (AP)5 Mar 2026
- Response of the President of the Administrative Jurisdiction Division to the draft AI Regulation Implementation ActLetter of 8 July 2026 from the President of the Administrative Jurisdiction Division to the Ministry of Justice and Security, with response and implementing assessment to the draft bill. The Division endorses that market supervision of courts by courts takes place, but advises that the sandbox task and the agreements on uniform interpretation of terms should not apply to its President because this conflicts with judicial independence. It advises expanding its own supervision to AI systems that fall only under the transparency obligations, and signals a question of competence when it is unclear whether a system is prohibited or high-risk. The implementing assessment estimates approximately 1 full-time equivalent additional.PublishedOpinionCouncil of State, Administrative Jurisdiction Division8 Jul 2026