Since August 2, 2026, organizations have been subject to the transparency obligations set out in Article 50 of the EU AI Act. Article 50 introduces transparency requirements for providers and deployers in relation to certain AI system functionalities and use cases that may create transparency risks for individuals. Whilst much of the EU AI Act focusses on obligations on high-risk AI systems, Article 50 obligations may also apply to certain limited-risk systems. As a result, many organizations need to implement governance, disclosure, and content-labelling measures to ensure users are appropriately informed about the use of certain AI systems and AI-generated content.
Importantly, these obligations were largely unaffected by the implementation delays contained in the Digital Omnibus on AI (Regulation (EU) 2026/1744), except for the marking obligations contained in Article 50(2) of the EU AI Act, i.e. relating to AI systems that generate synthetic audio, image, video, or text content and that were placed on the market before August 2, 2026. Following the agreement reached between the Council and the European Parliament on May 7, 2026 (see the European Parliament procedure record), and formally adopted on June 29, 2026, the introduction of these marking obligations has been delayed until December 2, 2026.
