The transparency obligations under Article 50 of the AI Act start on 2 August 2026 and were not postponed by the Digital Omnibus. From that date an AI system that interacts directly with people must disclose that it is AI, generated audio, image, video and text must carry machine-readable marking as artificial, and deepfakes must be made recognisable as artificial. For generative systems that were already on the market before 2 August 2026, the machine-readable marking under Article 50(2) has a transition period until 2 December 2026.
For many organisations this is the sharpest AI Act deadline with enforcement in 2026. Whereas the high-risk obligations from Annex III were moved through the Digital Omnibus to 2 December 2027, Article 50 stays on 2 August 2026. The Digital Omnibus was published by the Commission on 19 November 2025, reached a provisional political agreement on 6 and 7 May 2026 and was endorsed by the European Parliament on 16 June 2026, but as of late June 2026 it has not been formally adopted and has not appeared in the Official Journal. Until that publication, the original text of Regulation (EU) 2024/1689 remains legally controlling. Below you will read what Article 50 asks exactly, who must do what per role, and which steps to take now.
What does Article 50 ask exactly?
Article 50 governs transparency: people must know when they are dealing with AI or looking at AI-generated content. It is not a high-risk regime. There is no conformity assessment, no technical documentation under Annex IV and no registration in an EU database required. The duty is more direct: make the use of AI known, at the latest at the first interaction or exposure, in a clear and distinguishable way, and accessible to people with a disability.
The obligations fall into four parts, divided between providers and deployers. A provider develops the AI system or places it on the market under its own name. A deployer puts the system into use under its own responsibility. Many organisations are provider and deployer at the same time for different systems, and must therefore determine per system which duty falls to them.
Who must do what, per role?
The table below sets the four parts of Article 50 against the role that carries the obligation and the date it applies.
| Part | What | Role | Applies |
|---|---|---|---|
| 50(1) | Disclose a chatbot or AI interaction | Provider | 2 August 2026 |
| 50(2) | Machine-readable marking of generated audio, image, video, text | Provider | 2 August 2026, existing systems until 2 December 2026 |
| 50(3) | Inform people exposed to emotion recognition or biometric categorisation | Deployer | 2 August 2026 |
| 50(4) | Visibly mark deepfakes and certain AI text for public information | Deployer | 2 August 2026 |
Article 50(1) falls to the provider. A system intended to interact directly with people, such as a chatbot or virtual assistant, must be designed so that the person knows they are talking to AI. This is not required where that is obvious to a reasonably observant person.
Article 50(2) also falls to the provider and is technically the most demanding duty. Generative systems that produce audio, image, video or text must mark that output in a machine-readable format and make it detectable as artificially generated or manipulated. This touches on watermarking and provenance standards such as C2PA. An exception applies to systems with a purely assistive, editorial function, such as a spell checker.
Article 50(3) falls to the deployer. Anyone deploying a system for emotion recognition or biometric categorisation must inform the people exposed to it. Note that certain forms of emotion recognition are already prohibited as a banned practice since 2 February 2025, so check Article 5 first before relying on the transparency route.
Article 50(4) also falls to the deployer and has two branches. Anyone who generates or manipulates a deepfake must disclose that the content is artificial. For artistic, creative, satirical or fictional work a lighter form applies: the disclosure may not get in the way of enjoying the work. In addition, AI-generated text published to inform the public on matters of public interest must be marked as such, unless the text has been reviewed under human editorial responsibility.
Many organisations are provider and deployer at the same time. Anyone who integrates an external model into their own service is often in a mixed position and must set out contractually who delivers the machine-readable marking. Settle that agreement before the system goes live.
What is the role of watermarking and the transition period?
The machine-readable marking under Article 50(2) is the only duty with a separate transition period. Generative AI systems that were already on the EU market before 2 August 2026 get until 2 December 2026 to put that marking in order. For systems placed on the market after 2 August 2026, the obligation applies immediately from that date. So treat 2 December 2026 as a safety net for existing systems, not as the standard deadline.
The other three parts of Article 50 have no transition period. Chatbot disclosure, informing people about emotion recognition or biometrics, and the marking of deepfakes and public AI text all apply in full from 2 August 2026.
Which steps do you take now?
A practical preparation runs in four steps that you can complete well before the deadline.
Inventory which systems fall under Article 50
Map which systems interact directly with customers or staff, which generate content that is published or shared, and which run on emotion recognition or biometrics. Each of those categories touches a part of Article 50.
Assign the role per system
Determine whether you are provider, deployer or both. The duties under 50(1) and 50(2) fall to the provider, those under 50(3) and 50(4) to the deployer. For external models, set out contractually who provides the marking.
Set up the disclosure and the marking technically
Add the chatbot disclosure, arrange the notice for biometrics or emotion recognition, and prepare the machine-readable marking via standards such as C2PA. This is the part that takes the most lead time, because watermarking and provenance signals are not in place overnight.
Build an evidence layer
Article 50 does not require a formal conformity assessment, but on a complaint a supervisory authority will want to see that the disclosure was there and how it was designed. Keep screenshots, configurations and internal policy, so you can show that the notice was present from the first interaction.
What happens in case of non-compliance?
From 2 August 2026 Article 50 falls under the enforcement of the competent national supervisory authorities. In the Netherlands, supervision of the AI Act is being set up with the Dutch Data Protection Authority and the Dutch Authority for Digital Infrastructure in a coordinating role. For a breach of the transparency obligations a fine via the supervisory authority can follow, which under the regulation can run up to 15 million euro or 3 percent of total worldwide annual turnover, whichever is higher. That makes Article 50 the sharpest deadline with enforcement of 2026.
How do you put this into practice?
The legal explanation is one thing, the implementation another. For execution, Embed AI runs an Article 50 transparency check: a focused scan that determines the role per system, runs through the four parts, sets up the disclosure and marking, and orders the evidence layer. That connects to the broader AI governance scan and the Readiness Sprint in which transparency comes together with inventory, risk classification and governance.
The human side of transparency starts with awareness. Staff must recognise when a system falls under Article 50 and know that the disclosure belongs there. LearnWize makes that staff awareness demonstrable per role with assessments, learning paths and training records, so the human layer is in order alongside the technical marking. For broader background on the deadline and its relation to the Digital Omnibus, see the AI Act readiness roadmap.
Frequently asked questions about Article 50 transparency
Short, citable answers for organisations preparing for 2 August 2026.