EU Article 50 Consultation Closes; August 2 Transparency Cliff Now Locked In
The European Commission's targeted consultation on Article 50 transparency obligations closed today, with the final Code of Practice on AI-generated content marking due before the end of June and the underlying rules going live August 2, 2026.
The European Commission published its draft Article 50 guidelines on May 8 and accepted comments through today, June 3. The substance has not been a moving target since early May: the four obligations that take effect August 2 are interactive-AI disclosure (Article 50(1)), notice for emotion recognition systems, notice for biometric categorisation, and machine-readable marking plus user-facing labelling of synthetic and deepfake content (Article 50(4)). What today's deadline locks in is the timeline, not the rules.
The May 7 provisional agreement on the Digital Omnibus on AI added one significant carve-out. Providers of general-purpose generative AI systems already on the EU market before August 2 receive a transitional period running through December 2, 2026 to bring those systems into compliance. Systems placed on the market or put into service on or after August 2 must comply from day one — there is no on-ramp for new launches. The Code of Practice on marking and labelling of AI-generated content is expected to land in final form before the end of June, supplying the technical standards (watermark formats, metadata schemas, label placement) that map the statutory text onto product implementations.
The Article 50 regime has extraterritorial reach. A U.S.-headquartered model provider whose output reaches an EU end user is in scope, regardless of where inference runs. Combined with the Article 5 prohibited-practices rules already in force since February 2025 and the upcoming high-risk classification obligations, August 2 marks the point at which the AI Act becomes a fully operational compliance regime rather than a phased rollout.
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