On 20 July 2026 the European Commission published guidelines on the Article 50 transparency obligations of the EU AI Act, which apply to providers and deployers from 2 August 2026.
What happened
On 20 July 2026, the European Commission published guidelines detailing the transparency obligations set out in Article 50 of Regulation (EU) 2024/1689 (the EU AI Act). The guidelines are intended to help national competent authorities, providers, and deployers apply these obligations consistently across the Union.
The timing is notable: the guidance lands less than two weeks before Article 50 itself enters into application on 2 August 2026 — a deadline that reaches far more organizations than the high-risk obligations under Title III, since it applies to any provider or deployer whose systems fall within scope, regardless of risk classification.
Who is affected
Two categories of actors are addressed:
- Providers, who design and place on the market AI systems that pose transparency risks to the people who interact with them or are exposed to their output.
- Deployers, who put these systems into use and, for certain categories, carry a direct disclosure obligation toward the individuals concerned.
Recap: what Article 50 requires
Article 50 sets out four distinct obligations, depending on the type of AI system:
- Conversational systems (chatbots, voice assistants): providers must design the system so that natural persons are informed they are interacting with an AI system, unless this is obvious from the perspective of a reasonably well-informed person.
- Synthetic content (AI-generated or manipulated text, image, audio, video): providers must ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated.
- Emotion recognition and biometric categorisation systems: deployers must inform the natural persons exposed to the system's operation, and comply with applicable personal data processing requirements.
- Deepfakes and AI-generated text published on matters of public interest: deployers must disclose that the content has been artificially generated or manipulated.
Exemptions exist where use is authorised by law to detect, prevent, or investigate criminal offences, where content undergoes human editorial review with editorial responsibility, or for works that are manifestly artistic, creative, satirical, or fictional — subject to appropriate disclosure safeguards.
What this means in practice
The guidelines do not change the text of Article 50 itself, but they clarify how the Commission expects national market surveillance authorities to interpret and enforce these obligations consistently. For organizations building or deploying AI systems in the EU, this means:
- Checking, before 2 August 2026, whether any deployed system falls into one of the four categories above — irrespective of its risk classification under Title III.
- Documenting how end users are informed (in-interface disclosures, content labelling, notices).
- Aligning this compliance work with the Code of Practice on transparency for AI-generated content, which the Commission references as a complementary benchmark for labelling synthetic content.
The compressed timeline — guidance published less than two weeks before the obligation takes effect — means compliance teams should treat this as an immediate priority alongside ongoing Annex III and GPAI workstreams.
For more detail, see our dedicated pages on transparency obligations and providers vs. deployers.
Official source
European Commission — Guidelines on transparency obligations for providers and deployers of certain AI systems, published 20 July 2026.
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