Article 50: transparency
Specific disclosure, marking and labelling duties for certain AI systems and synthetic content.
The official source remains authoritative. This general interpretation is not legal advice.
- Status
- Applicable
- Application date
- 2 August 2026
- Version
- 1.0.0
- Last reviewed
- 8 August 2026
Who this is relevant to
When this applies
Deployer
An organisation using an AI system under its authority, excluding personal non-professional use.
Provider of an AI system
A party that develops or has an AI system developed and places it on the market under its own name.
- 1An AI system is intended to interact directly with natural persons.
- 2The system generates or manipulates synthetic audio, image, video or text, or the use concerns a specifically listed deployer scenario.
What the official source establishes
Article 50 applies since 2 August 2026. The precise duty differs by scenario: direct AI interaction, machine-readable marking, emotion recognition or biometric categorisation, deepfakes and certain public-interest text.
Our interpretation
A generic rule that all AI content must always carry a visible label is too broad. First classify the specific Article 50 scenario.
What you can do now
For each system, record the applicable paragraph, responsible actor, implemented disclosure or marking and how it was tested.
- 01
Implement the applicable disclosure, marking or label
First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
What to retain
Transparency implementation record
Record of scenario, actor, disclosure or marking, technical implementation, test and owner.
Control and reassessment
Pre-release transparency check
Before release, test that the applicable disclosure, marking or label is timely, clear and technically effective.
Public tools
Article 50 checklist
Public decision route for the distinct transparency obligations.
Conditions and exceptions
- The direct-interaction disclosure is not required where this is obvious to a reasonably well-informed, observant and circumspect person, considering circumstances and context.
- Only Article 50(2) has a transition until 2 December 2026 for systems placed on the market before 2 August 2026.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 50(1)-(5) and Article 113
Guidelines on Article 50
European Commission | final-2026-07-20
Source locator: Final guidelines, scope by Article 50 paragraph
Guidelines on Article 50
European Commission | final-2026-07-20
Source locator: Implementation guidance for providers and deployers
What changed in this
Moments when this obligation took effect, moved or received official guidance.
2026-12-02 | upcoming
Grace period for machine-readable marking ends
Systems placed on the market before 2 August 2026 must comply with Article 50(2) by 2 December 2026.
2026-08-02 | applicable
Article 50 is applicable
The transparency duties apply since 2 August 2026.
2026-07-20 | guidance
Final guidelines on Article 50
The Commission works out the transparency duties and confirms they apply from 2 August 2026.
2026-06-10 | guidance
Transparency Code of Practice published
A voluntary route to comply with parts of Article 50, in two separately signable sections.
What member states are doing with this
Dated signals from the enforcement tracker that refer to this obligation.
Estonia | 2026-08-05 | Justiits- ja Digiministeerium
Ministry of Justice and Digital Affairs explains Article 50 transparency obligations
Immediately after 2 August 2026 the Estonian Ministry of Justice and Digital Affairs published official guidance on the new transparency obligations for AI-generated content and deepfakes, including potential fines of up to EUR 15 million or 3 percent of global annual turnover. The communication does not yet name a national supervisory authority.
Justiits- ja Digiministeerium (Ministry of Justice and Digital Affairs)
EU | 2026-08-02 | Europese Commissie / AI Office
GPAI and Article 50 enforcement powers active
Since 2 August 2026 the European Commission, through the AI Office, can enforce the GPAI obligations and national authorities are competent to enforce the Article 50 transparency obligations. Most other AI Act obligations also apply from this date.
EU | 2026-08-02 | Europese Commissie / AI Office
Commission enforcement powers for GPAI and national Article 50 enforcement active
Through the AI Office the Commission can now request documentation, run technical evaluations of models, order measures and market withdrawal, and impose fines of up to 3 percent of global annual turnover or 15 million euros on GPAI model providers. The AI Office indicated it will first rely on technical compliance dialogues. National enforcement of the Article 50 transparency obligations also became active on this date.
EU | 2026-08-02 | Europese Commissie / AI Office en nationale markttoezichtautoriteiten
Enforcement powers for GPAI and transparency obligations become active
Since 2 August 2026 the European Commission, through the AI Office, can enforce the rules for providers of general-purpose AI models and national market surveillance authorities can enforce the Article 50 transparency obligations. For the countries in this cluster this means ACN, AESIA, ANACOM, HDPA, MDIA and OCECPR can take real action from this date.
EU | 2026-08-02 | Europese Commissie / AI Office
Enforcement of GPAI rules and Article 50 transparency begins
Since 2 August 2026 the Commission, through the AI Office, can enforce the rules for general-purpose AI models and national market surveillance authorities must enforce the Article 50 transparency obligations. In this cluster only Hungary and Slovenia are institutionally ready; Poland follows from 11 August 2026 when its implementing act enters into force.
Version history
v1.0.0
2 August 2026
Article 50: transparency
Specific disclosure, marking and labelling duties for certain AI systems and synthetic content.
Execution
Make Article 50 arranged and demonstrable
Disclosure, labelling and marking apply now. Embed AI maps your role and the matching transparency measure per AI use case, with the evidence file to match.
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