By Rafael Luque Ocaña

Article 50 transparency, in application since 2 August 2026

2 August 2026: the AI Act's transparency obligations move from a date on a calendar to a rule in application. What exactly changes that day, for whom — and why, for those who did their homework in July, entry into application demands nothing special.

Today, 2 August 2026, the transparency obligations of Article 50 of the AI Act enter into application. After months of countdown, the date is no longer in the future. It deserves a brief note — precisely because, if the work is done, nothing spectacular happens today. And that's the point. It concerns anyone who provides or uses systems that converse with people or generate content.

What exactly changes today

From today, for every system Article 50 reaches — those already in use and those added later —:

  • Systems that interact with people must make it known that they are AI — with the division of roles we already explained: the design is the provider's; the diligent verification, the deployer's.
  • Synthetic content must be marked by its provider, and the deployer must disclose deep fakes and declare text published to inform the public — except via the editorial review route, which for most SMEs that publish with editorial judgement is the natural coverage.
  • And as we reported this week, the market surveillance machinery that can ask about all of the above also starts up.

One transitional nuance worth keeping in mind: providers of generative systems placed on the market before today have until 2 December 2026 to comply with the Article 50(2) marking. It is neither an extension nor a general second chance: it is a transitional period created by Regulation (EU) 2026/1744, limited to those systems and their providers.

Article 50: who owes each transparency dutyArticle 50(1) to (4) of Regulation (EU) 2024/1689EACH PARAGRAPH HAS ITS OWN SUBJECT: TWO FALL ON THE PROVIDER, TWO ON THE DEPLOYERYESYESYESYESYour AI system · each question is answered on its ownDoes it interactwith people?ART.50(1)Providerdesign it so peopleknow they areinteracting with AI,unless that is obviousDoes it generatesyntheticcontent?ART.50(2)Providermark outputs in amachine-readable,detectable format;except standardediting support or notsubstantially alteringthe input dataEmotionrecognition orcategorisation?ART.50(3)Deployerinform the peopleexposed of how thesystem operates andprocess data under theGDPRDeep fake ortext on publicmatters?ART.50(4)Deployerdisclose it isartificial; for text,unless human review oreditorial control anda person holdseditorialresponsibilityArt.50(1)-(4) of Regulation (EU) 2024/1689 · Regulation (EU) 2026/1744 only replaces paragraph 7
Each paragraph of Article 50 binds a different subject, and the same system may trigger several or none. All four exempt uses authorised by law for criminal-law purposes — in Article 50(1), unless the system is available for the public to report a criminal offence — and for evidently artistic, creative, satirical, fictional or analogous works the Article 50(4) duty is limited to disclosing that the content exists. When each one applies is on the calendar.

The figure allocates the four duties of Article 50: the notice that people are interacting with an AI system and the marking of synthetic content fall to the provider; the information on emotion recognition or biometric categorisation and the disclosure of deep fakes and of text published to inform the public on matters of public interest, to the deployer.

If you closed out July, today is Monday

The closing checklist we published a few days ago was exactly this: the sublist of affected systems, the chatbot check, the labelling criteria, the editorial workflow, and the record of all of it. Whoever completed it has no new task today: their notices were already visible yesterday, their criteria were already written, their file already carries a July date. A rule's entry into application is a non-event for those who prepared — which is the best possible description of good governance.

Those who didn't get there shouldn't tell themselves stories, but shouldn't panic either: the five tasks on that checklist are still the same, they still take days rather than months, and every day they're done and recorded is a day less of exposure. Starting late is worse than starting on time, and far better than not starting.

What comes next

The calendar doesn't stop here. On 2 December 2026 the marking transitional period expires for providers of systems that predate today, and the new Article 5 prohibitions on systems generating child sexual abuse material and non-consensual intimate images start applying, on the date set by Regulation (EU) 2026/1744. Beyond that, high risk under Annex III arrives on 2 December 2027 under the calendar set by the Digital Omnibus. Every date, like this one, will reward the same thing: having arrived with the evidence already built.

Today transparency stops being a plan. Welcome as it is: it was the most reasonable obligation in the Regulation, and the cheapest to get right.

Article 50 series → the four paragraphs on one page.

This article is for informational purposes only and does not constitute legal advice.

Frequently asked questions

What changed on 2 August 2026?

The Article 50 transparency obligations started to apply: the notice of interaction with an AI system and the marking of synthetic content, for the provider; the information on emotions and biometrics and the disclosure of deep fakes and text of public interest, for the deployer.

Is there any transitional period?

Only one: providers of generative systems placed on the market before 2 August 2026 have until 2 December 2026 for the Article 50(2) marking.

What comes next?

On 2 December 2026 that transitional period ends and the new Article 5(1)(ba) and (bb) prohibitions start applying. High risk under Annex III arrives on 2 December 2027.

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