The European Commission published its final Article 50 transparency guidelines on July 20, 2026, giving providers and deployers of AI systems nine days to comply before the rules bind on Sunday, August 2. TechTimes reports the date won’t slip.

The 51-page document is formally non-binding. In practice, Bird & Bird expects the 27 national market surveillance authorities to treat it as the primary enforcement reference, which makes the distinction academic. Penalties run up to €15 million or 3% of worldwide annual turnover, whichever is higher.

Article 50 splits obligations three ways. Providers must notify users when they’re interacting with an AI system and embed machine-readable marks in synthetic output. Deployers must disclose emotion-recognition and biometric-categorisation use, and label deepfakes. Enforcement is shared: national authorities handle most cases, while the AI Office takes systems built on general-purpose models by the same provider, or integrated into VLOPs and VLOSEs under the DSA.

The final text softened the May draft in two places. There’s no retroactive labelling for image, audio, or video deepfakes generated before August 2. For AI-written text on matters of public interest, the trigger is the publication date, so text drafted earlier but published on or after August 2 still needs a label, absent the editorial-control exception.

The guidelines concede that reliable watermarking standards for audio, images, video, and text that survive compression don’t yet exist. Technical standards are still being worked through the Code of Practice on Transparency, whose July 22 signing deadline has already passed. Signatories get a presumption of conformity; the rest build their own evidence.

Meanwhile the Digital Omnibus, adopted by the Council on June 29 as Omnibus VII, pushed high-risk AI obligations to December 2027 and August 2028, and cut the grace period for marking pre-existing generative content from six months to three, landing on December 2, 2026. Brussels blinked on the hard parts. Article 50 wasn’t one of them.

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