The labelling rule has guidance now, and it names the hard part
The Commission's 17 August guidance covers labelling, user notices, logging, documentation and internal approval workflows. Four of those five are paperwork. The one that is not is the one that decides whether a label survives.
The Commission's transparency guidance, published 17 August, sets out five areas: labelling requirements, user notices, logging practices, technical documentation and internal approval workflows for AI-generated or AI-assisted content.
Which of these actually binds
Documentation and logging are auditable after the fact — real obligations, but ones an organisation can satisfy retrospectively with effort. User notices are a product change made once. Labelling is different: it has to happen at generation time, survive every downstream transformation, and still be present when a person finally sees the content.
For text that chain is short. For image, audio and video it runs through colour correction, cropping, recompression, platform upload, re-encoding and screenshotting — and most of those steps are performed by software that has never heard of the obligation.
The approval workflow is the sleeper
Of the five, internal approval workflow is the one most organisations do not have. It requires a defined moment where somebody confirms generated content was marked before it shipped. That is a process change, not a technical one, and it is the item that will be missing when an enforcer asks.
The word doing the most work
"Materially altered." A model that sharpens a photograph has altered it; whether it has materially altered it is a judgement now being made in code, at pipeline scale, by teams with no guidance on where the line sits — and made by default in consumer photo tools that apply generative enhancement without anyone choosing it.
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 →