The Week in One Line

While most attention has focused on the delayed high-risk deadlines, one transparency obligation actually became stricter. The transitional period for certain Article 50 watermarking requirements was shortened, moving the compliance date for eligible existing systems to 2 December 2026.

What the Act Actually Says

Article 50 requires providers of AI systems that generate synthetic text, images, audio, or video to ensure that outputs are marked in a machine-readable format identifying that the content was artificially generated or manipulated.

Deployers of certain AI systems also have transparency obligations, including informing people when they are interacting with AI in situations covered by Article 50.

Before the May 2026 Digital Omnibus agreement, AI systems already placed on the market before 2 August 2026 would have benefited from a six-month transitional period before certain Article 50 watermarking requirements applied.

The Omnibus agreement shortened that transitional period to three months, moving the compliance date for those existing systems to 2 December 2026.

This is one of the few areas where the recent Omnibus negotiations became more stringent, while many other AI Act deadlines were postponed.

The broader Article 50 transparency obligations, including disclosure requirements for certain AI interactions and synthetic content, remain scheduled to apply from 2 August 2026.

Sources: European Commission Article 50 guidance and Code of Practice on Transparency of AI-Generated Content; EU AI Act Service Desk (Article 50); Gibson Dunn analysis of the Digital Omnibus.

What This Means for Your Business

If your product generates synthetic text, images, audio, or video, or presents AI-generated content to users, now is the time to determine which Article 50 transparency obligations apply.

Three months of engineering time is not a lot.

If watermarking or content labelling has not yet been scoped, it should move up your priority list.

Determine whether your organisation is acting as the provider or the deployer for each AI feature. The obligations differ depending on your role in the value chain.

For many organisations building generative AI features, Article 50 compliance may arrive before many of the delayed high-risk obligations.

Prioritise accordingly.

This Week's Action Point

Audit every product feature that generates:

  • Text
  • Images
  • Audio
  • Video

For each feature, confirm:

  • Whether Article 50 applies.
  • Whether your organisation is the provider or the deployer.
  • What watermarking, machine-readable marking, or transparency disclosure mechanism must be implemented before 2 December 2026, where applicable.

Further Reading

  • European Commission – Code of Practice on Transparency of AI-Generated Content
  • EU AI Act Service Desk – Article 50
  • Gibson Dunn – EU AI Act Omnibus Agreement: Postponed High-Risk Deadlines and Other Key Changes

Next Tuesday

Small Mid-Caps: Who qualifies for the new compliance relief, and why many growing companies may be overlooking it.