What actually needs an AI label since 2 August 2026
The transparency duties became applicable on 2 August 2026 and were not deferred by the Digital Omnibus — it moved the high-risk dates, not these. But they are narrower than the summaries imply: the duties attach to what a system does, not to using AI at all.
A system intended to interact directly with people — a chatbot, a virtual assistant, a customer-service bot — must be designed so those people are told they are dealing with AI, unless it is obvious from the circumstances.
Synthetic audio, image, video or text generated by the system must be marked in a machine-readable way, so its origin can be detected.
Emotion recognition and biometric categorisation systems must inform the people exposed to them.
Deepfakes — content that would falsely appear authentic — must be disclosed as artificially generated or manipulated. The same limb covers AI-generated text published to inform the public on matters of public interest, unless a human took editorial responsibility for it.
What Article 50 does not require
The duty is per system and per use — which is why a summary that reads as “label everything” is wrong in both directions: it overburdens the internal tools that owe nothing, and it hides that a chatbot owes its disclosure today.
- A label on everything an employee produces with an internal tool
- A disclosure for a back-office model no person interacts with
- Any Article 50 duty at all for a system that neither interacts with people nor generates or manipulates content
The one grace period, providers only
Article 111(4) gives systems already placed on the market before 2 August 2026 until 2 December 2026 to comply with the Article 50(2) marking duty. Deployer duties under Article 50(3) and 50(4) had no grandfathering — they have been fully applicable since 2 August 2026.
Which systems of yours are caught
The rules that decide are deterministic: the same triggers the register runs against every system’s recorded description. Describe a system in the exposure scanner and it will tell you whether an Article 50 trigger matched — with the phrase that matched, so you can argue with it.
Regulatory content checked against the consolidated text of Regulation (EU) 2024/1689 as amended · see /regulatory-changelog