The Commission published the guidelines two weeks after the duty began
Transparency obligations became enforceable on 2 August. The guidance explaining how to comply arrived on 17 August. Fifteen days is not long, but the order is the wrong way round, and the penalty is €15 million or 3% of worldwide turnover.
The European Commission published guidance on 17 August setting out how providers and deployers should meet the AI Act's transparency obligations — labelling, user notices, logging, technical documentation and internal approval workflows. Those obligations became enforceable on 2 August.
Fifteen days is not a scandal. Regulators routinely publish interpretive guidance after a provision commences, and the underlying duty was legible from the text long before either date. But it does describe the position compliance teams have actually been in: obliged since the second, told how on the seventeenth.
What the guidance covers
The five areas named are practical rather than principled. Labelling and user notices are what a customer sees. Logging and technical documentation are what an auditor asks for. Internal approval workflows are the part most organisations do not have — a defined point at which somebody signs off that generated content has been marked as such before it ships.
That last one is where the obligation stops being a legal question. Whether a chatbot discloses itself is a product decision made by engineers, and it will not appear in a conformity matrix owned by counsel.
The number attached
Non-compliance carries fines up to €15 million or 3% of worldwide annual turnover, whichever is higher. For a large multinational the percentage is the operative figure, and it is calculated on global revenue rather than European revenue — a detail that decides whether this is a European compliance project or a corporate one.
What has not commenced
The high-risk regime is still ahead. Lawmakers agreed in May to postpone those obligations to 2 December 2027 as part of the Digital Omnibus package. Guidance published now concerns what is live now, and reading it as the whole Act is the error that has been running through coverage since the start of the month.
European Commission — Guidelines on transparency obligations under the AI Act → · Cooley — EU AI Act: Transparency Obligations Take Effect 2 August 2026 → · Al Jazeera — What came into force with the EU's AI Act this week — and what didn't → · Holland & Knight — US Companies Face EU AI Act's August 2026 Compliance Deadline →