European Union
EU AI Act — Article 50 (Transparency)
Regulatory content changes frequently. This page is informational only and should be verified with qualified counsel before reliance.
Applies to
Providers and deployers of AI systems serving EU audiences — with different duties. Machine-readable marking under Article 50(2) binds PROVIDERS of generative systems (deadline moved to December 2, 2026 for systems on the market before August 2, 2026, per the May 2026 Omnibus provisional agreement). Deployer duties are narrower, centered on disclosing synthetic media and AI interaction. Marketing agencies using AI tools are typically deployers.
Business impact
Agencies serving EU brands or audiences should not assume the obligations are purely the vendor's. Deployer-side transparency expectations apply now.
Disclosure relevance
If your agency produces public-facing AI-generated content for EU audiences, you need a repeatable process for labeling, review, and documentation.
Metadata relevance
Watermarking and content-provenance metadata is explicitly in scope for certain generated media.
Key obligations
- Transparency obligations for AI systems and AI-generated or altered content under Article 50
- Deployer-side duties (narrower): disclose synthetic media / AI interaction in public-facing contexts, from August 2, 2026
- Provider-side Article 50(2) machine-readable marking: moved to December 2, 2026 for systems already on the market before August 2, 2026 (May 2026 Omnibus)
- High-Risk AI System (HRAIS) obligations extended to Dec 2 2027 / Aug 2 2028 (per May 2026 Omnibus)
How Atlas² helps
We help build a labeling + documentation process for AI-generated media and map which obligations fall on you versus your tooling vendors.
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