Guides · Article 50 · EU AI Act
Article 50 applies from 2 August 2026 — the final-weeks checklist
The application date for Article 50 of the EU AI Act is now weeks away: its transparency obligations apply from 2 August 2026. For teams that have been putting this off, the remaining runway is short but workable — the duties turn on what kind of AI system you run, and most of the preparation is mapping and documentation rather than engineering.
This update collects the final-weeks steps in one place. It is informational only and does not determine whether the Act applies to you — scope is fact-specific and one to confirm with qualified counsel.
What changes on 2 August 2026
From that date, the four transparency duties in Article 50 apply: providers of AI systems that interact directly with people must ensure people are informed they are dealing with AI (50(1)); providers of systems generating synthetic audio, image, video, or text must mark outputs in a machine-readable format (50(2)); deployers of emotion-recognition or biometric-categorisation systems must inform the people exposed (50(3)); and deployers must disclose deepfakes and certain AI-generated public-interest text (50(4)). Article 50(5) adds the how and when: clear, distinguishable, at the latest at the first interaction or exposure, and meeting accessibility requirements.
It is an application date, not a filing deadline — nothing is submitted anywhere. What matters is that, from that day, the duties are in effect for systems in scope.
The final-weeks checklist
Working backwards from the date, this is the sequence teams are running now:
- Week 1 — inventory: list every AI system and AI feature you run, the output types each produces, and whether you are provider-side, deployer-side, or both for each.
- Week 1 — mapping: match each system to the Article 50 paragraph(s) it might engage; note any carve-outs you may rely on, with the reasoning written down.
- Week 2 — drafting: write the disclosures (chatbot notice, deepfake label) and choose the machine-readable marking approach for generated content.
- Week 2 — placement: confirm each disclosure appears at or before the first interaction or exposure, in the actual product, and meets accessibility requirements (Article 50(5)).
- Week 3 — review: route the documentation pack to qualified counsel, fix what they flag, and keep the evidence of what you shipped and when.
If you are starting late
Starting late narrows the order of operations rather than changing it: inventory and mapping first, because everything else depends on knowing which paragraph touches which system. Our free scope check walks the four paragraphs in about seven questions and gives an automated, informational indication of what may apply — a useful way to frame the counsel conversation quickly. It is not a determination that the Act applies to you.
Common questions
Is 2 August 2026 a filing or registration deadline?
No. It is the date from which Article 50's transparency obligations apply. There is nothing to file; the question is whether systems in scope meet the duties from that date. Whether yours are in scope is fact-specific — confirm with qualified counsel.
Can a small team realistically prepare in the remaining weeks?
The Article 50 duties are mapping-and-documentation heavy rather than engineering heavy for many systems, so a focused effort is often practical. How much work yours needs depends on the facts — an inventory is the fastest way to find out.
Sources
Drafted with AI assistance against the EUR-Lex Article 50 text; edited and fact-checked by Matthew Anglim.
See what may apply to your business
Answer seven quick questions for a free, automated indication of which Article 50 obligations appear likely to apply to your business.