Not legal advice. Use this checklist to prepare for legal review. Confirm applicability and deadlines with qualified counsel.
Effective date
Article 50 transparency obligations: 2 August 2026 (confirm applicability to your use case with counsel).
The Commission published implementation guidelines on 20 July 2026. First map the feature to direct interaction, output marking, emotion / biometric notice, or deployer publication disclosure. The transition to 2 December 2026 is limited to relevant pre-existing systems under the Article 50(2) marking and detection duty — it is not a blanket extension.
Checklist
[ ] Inventory direct AI interactions, generated-content surfaces, and external publications
[ ] Record whether you are provider, deployer, or both for each surface
[ ] Map each surface to Article 50(1), (2), (3), or (4)
[ ] Draft clear “you are interacting with AI” notice where Article 50(1) applies
[ ] Assess machine-readable marking for generated / manipulated outputs under Article 50(2)
[ ] Label deepfakes or relevant public-interest text where Article 50(4) applies
[ ] Check exceptions and whether the limited December transition is relevant
[ ] Align marketing claims with real model behaviour
[ ] Document who owns disclosure copy
[ ] QA that disclosure appears in all surfaces (web, app, email)
[ ] Save screenshots, release version, approval date, and implementation owner