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The EU Code of Practice on Transparency of AI-Generated Content gives businesses a voluntary way to implement and demonstrate certain transparency duties under Article 50 of the AI Act. The duties themselves are not voluntary: they have applied since 2 August 2026. Signing the code can provide a recognized compliance route, but does not by itself prove that an organization complies.
What is the Code of Practice on Transparency of AI-Generated Content?
Published by the European Commission on 10 June 2026, the code is a practical framework for providers and deployers addressing specified transparency requirements in Article 50 of the EU AI Act. The Commission and the AI Board assessed it as adequate for the relevant obligations in Article 50(2), (4), and (5). The Commission’s code page describes it as voluntary while emphasizing that the underlying legal duties are binding.
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The code has two sections. Providers make or supply AI systems and are concerned chiefly with marking and detecting AI-generated or manipulated content. Deployers use AI systems and may have to disclose certain AI-generated or manipulated output. A business can occupy both roles and may sign both sections.
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Provider commitments: marking and detection
The provider section addresses generated or manipulated audio, images, video, and text. It calls for machine-readable marking and detection methods that are effective, interoperable, robust, and reliable as far as technically feasible. Implementation should account for the content type, technical limits, costs, and state of the art; the code does not establish a universal detection accuracy or prescribe one tool for every use.
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Deployer commitments: labels for specified content
The deployer section focuses on deepfakes and AI-generated or manipulated text published to inform the public on matters of public interest. It offers guidance on the design and presentation of labels, disclaimers, and icons. Its approach also addresses creative, satirical, fictional, or analogous works and the significance of human review and editorial responsibility. The code provides an optional EU icon in three variants.
Does the code impose additional obligations beyond the AI Act?
No. The code does not create obligations beyond Article 50, and adherence is optional. The Article 50 transparency duties that apply to a business remain legal obligations whether or not it signs. The Commission concluded its adequacy assessment on 8 July 2026, and the AI Board adopted its assessment on 9 July. The Commission’s adequacy assessment notice says: “Adherence to the code does not constitute conclusive evidence of compliance with these obligations.”
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Signatories may rely on the code’s measures as a recognized means of demonstrating compliance. That is useful evidence, not a safe harbor: an organization remains accountable for whether its measures actually meet the law. A business choosing another implementation route must be prepared to show that its alternative measures are adequate; authorities assess alternatives individually.
Who is eligible to sign up to the code?
Providers and deployers can sign the section relevant to their role. Organizations that perform both roles may sign both. The Commission’s signing FAQ also identifies providers of tools, services, or infrastructure for AI content marking, provenance, watermarking, and detection as eligible participants.
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Signing is by section: an organization cannot select only individual commitments within a section. The initial-signatory submission deadline was 27 July 2026 at 18:00 CEST, but missing that deadline does not bar later participation. The Commission says providers and deployers may in principle sign later by submitting the form. About 190 companies and organizations had signed by the end of July 2026, according to the Commission; this is a dated count, not a live total.
What are the consequences of not signing the code?
Not signing does not remove or reduce applicable Article 50 duties. It means the organization cannot rely on adherence to this code as its chosen means of demonstrating compliance. A non-signatory can use another adequate approach, but should document its rationale, measures, and evidence and be ready to explain them to the relevant market-surveillance authority. A gap analysis against the code can help identify issues, although it is not itself a legal requirement.
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The Commission’s Article 50 guidelines clarify definitions, scope, examples, and exemptions. The code and guidelines should be read together: the code offers implementation measures, while the guidelines explain how the law applies. The Commission describes a transitional period until 2 December 2026 for certain systems placed on the market before 2 August 2026. That transition is limited; confirm the system and applicable guidance before relying on it rather than assuming it covers every duty or output.
How should a business decide which route to take?
Start with the legal situation and the organization’s role, not with a preferred product. The Commission’s official materials do not establish a universal ranking of vendors or tools.
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- Identify your role. Determine whether your organization provides an AI system, deploys one, or does both; assess the relevant code section or sections accordingly.
- Map the output or interaction. Distinguish generated or manipulated media, deepfakes, public-interest text, and direct AI interactions. The specific Article 50 duties and any exceptions depend on the category and circumstances.
- Choose an implementation route. Decide whether to adhere to the relevant code section or use alternative measures. If choosing an alternative, record why it is adequate for the applicable duty.
- Evaluate technical measures. For marking and detection, consider effectiveness, interoperability across audio, images, video, and text, robustness, reliability, feasibility, cost, and the state of the art.
- Keep evidence. Preserve the measures used, the decisions behind them, and documentation that can support an explanation to the relevant authority.
How do I label AI-generated content?
There is no blanket rule in this code that every AI-generated text must carry a visible label. For deployers, the code’s labeling guidance is directed at deepfakes and AI-generated or manipulated text published to inform the public on matters of public interest, subject to the law’s scope and applicable exceptions. Assess the content, purpose, human review, and editorial responsibility before deciding what disclosure is required.
Where a label is required, follow the code’s guidance on presenting labels, disclaimers, or icons so they communicate the relevant information clearly. The optional EU icon is one available approach, not a substitute for determining whether a disclosure is legally required or whether the chosen presentation meets the applicable duty. Providers should address machine-readable marking and detection separately from a deployer’s user-facing label obligations.
Quick Recap
What the code does—and does not—settle
- It offers: a common, EU-wide implementation framework and a recognized way for signatories to demonstrate measures for specified Article 50 duties.
- It does not offer: a guarantee of compliance, an exemption for non-signatories, or a universal technical tool or accuracy benchmark.
- It does not replace: the AI Act or the Commission’s Article 50 guidelines.
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