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Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Clear out junk files and repair common Windows errorsFree Scan →As of 4 October 2026, Article 50 of the EU AI Act applies: covered AI providers and deployers must meet specific transparency duties, but the law does not require a visible label on every AI-assisted marketing asset. A limited transition runs until 2 December 2026 for providers’ machine-readable marking of outputs from certain systems already on the market; it does not postpone the other Article 50 duties.
When do the transparency rules apply?
Article 50 of Regulation (EU) 2024/1689 applies from 2 August 2026. That is the date to use when asking when the transparency obligations begin to apply—not a general enforcement grace period.
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| Date | What it means |
|---|---|
| 2 August 2026 | Article 50 transparency duties begin to apply. |
| 2 December 2026 | Final date for providers of covered AI systems that generate synthetic audio, image, video or text and were placed on the market before 2 August 2026 to take the necessary steps for the marking duty in Article 50(2). |
The December transition is narrow: it concerns the provider’s machine-readable marking duty for the specified pre-existing systems. It does not delay chatbot notices, deployer disclosures or the other Article 50 requirements.
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Who has duties: the provider, the deployer, or both?
The Act assigns duties by role and use, not by job title. A provider places an AI system on the market or puts it into service; a deployer uses an AI system under its authority. A product team may be acting as a provider, while a marketing team using a vendor’s tool may be a deployer. An organisation can have different roles across different systems and workflows.
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“AI product” and “marketer” are useful shorthand, not separate statutory categories. For each use, work out who supplies the system, who operates it, what the system does and what people encounter.
What does Article 50 require?
| Use or output | Who must act | Transparency duty | Boundary or exception |
|---|---|---|---|
| AI system intended to interact directly with people | Provider | Design and develop the system so people are informed that they are interacting with AI. | No notice is required under this provision when that fact is obvious to a reasonably well-informed, observant and circumspect person in the circumstances and context of use. |
| System generating synthetic audio, images, video or text | Provider | Ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated. Solutions should be effective, interoperable, robust and reliable as far as technically feasible, taking account of content-specific limits, implementation costs and the state of the art. | The Act specifies exceptions, including certain assistive editing and criminal-law uses. The limited pre-existing-system transition is set out above. |
| Emotion-recognition or biometric-categorisation system | Deployer | Inform people exposed to the system that it is operating. | The Act provides a specified exception for certain law-enforcement uses. |
| AI-generated or AI-manipulated image, audio or video that constitutes a deepfake | Deployer | Disclose that the content was artificially generated or manipulated. | For evidently artistic, creative, satirical, fictional or analogous works, disclosure is limited to acknowledging the generated or manipulated content in a suitable way that does not hamper the work’s display or enjoyment. |
| AI-generated or AI-manipulated text published to inform the public on a matter of public interest | Deployer | Disclose that the text was artificially generated or manipulated. | The disclosure exception requires human review or editorial control and a natural or legal person who holds editorial responsibility for the publication. |
Required information must be clear and distinguishable no later than the person’s first interaction with or exposure to the system or content, as applicable, and must meet accessibility requirements. The notice to a person and the machine-readable marking of generated output are separate mechanisms: one does not automatically satisfy the other.
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Does every AI-generated marketing asset need a visible label?
No. Article 50 does not create a blanket rule that every asset made with AI must carry a visible “AI-generated” label. The applicable duty depends on the system, the organisation’s role, the output and its context. For example, the provider’s output-marking duty is technical and machine-readable; the deepfake and public-interest-text disclosure duties apply to defined categories of content used by deployers.
That does not mean marketing content can be treated as automatically out of scope. A campaign image or video may meet the deepfake threshold; an AI-written publication may fall within the public-interest-text rule. Assess the actual content and how it will be used or published, rather than assuming that an advertisement, social post or other marketing format is always covered—or always exempt.
What should marketing and product teams change?
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Map systems and workflows
Inventory AI use in EU-facing products, customer support, advertising, social publishing and editorial work. For each workflow, record the supplier and operator, the likely provider or deployer role, the output type, any substantial alteration, the intended audience and context, and whether the result might be a deepfake or public-interest text.
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Review direct interactions
For chatbots and other systems intended to interact directly with people, make the AI nature clear at the first interaction when it is not already obvious in context. Check the actual interface and user journey, not only the product description or terms.
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Check vendor marking capabilities
Ask providers how covered outputs are marked and how the marking can be detected. A visible badge on an asset, by itself, does not establish that the output carries machine-readable marking. Conversely, Article 50 does not say every AI-assisted marketing asset must display a visible badge.
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Set review and disclosure gates
Route potentially deepfake image, audio and video content, and public-interest text, through a decision process before publication. For the text exception, human review or editorial control must be accompanied by accountable editorial responsibility; human involvement alone does not meet the full test.
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Make notices usable
Place any required information where it is clear, distinguishable and timely, and check that it meets applicable accessibility requirements. A disclosure that people cannot readily notice may not serve the statutory purpose.
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Keep operational evidence
It is prudent to retain role assessments, content classifications, vendor capability information, editorial decisions and copies or records of notices. Article 50 does not prescribe a particular recordkeeping template, so do not present an internal checklist as a statutory form.
How guidance and enforcement fit in
The European Commission’s guidance discusses the rules’ definitions, scope, exceptions, examples and ways to demonstrate compliance. Its Code of Practice offers signatories a practical implementation framework, but it does not replace Regulation (EU) 2024/1689 or the Commission guidance. Article 50 also leaves other applicable Union and national transparency obligations unaffected, so an Article 50 assessment is not a complete legal review of every notice a product or campaign may need.
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A free scan shows the junk files, broken settings and background clutter dragging Windows down - then fixes them in one click.Free scan · Windows 10 & 11Enforcement responsibilities depend on the context. The Commission identifies national market-surveillance authorities, the AI Office for systems under its supervision, and the European Data Protection Supervisor for EU institutions as relevant enforcement actors in their respective areas. The applicable obligations already have an application date; which authority is relevant depends on the system and organisation involved.
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