The EU AI Act’s Article 50 transparency obligations took effect on 2 August 2026. Any company deploying a chatbot, virtual assistant, or conversational AI system must now disclose to users that they are interacting with AI. Any company generating synthetic audio, images, video, or text must mark that output as artificially generated. Deepfake content requires explicit disclosure. These rules apply now, regardless of sector or company size.
The high-risk obligations, which were originally due on the same date, have been deferred. The Digital Omnibus on AI was signed on 8 July after the Council gave final approval on 29 June. Standalone high-risk AI systems listed under Annex III now have until 2 December 2027 to comply. This covers companies using AI for recruitment and hiring decisions, credit scoring, educational assessment, biometric identification, law enforcement support, border control, and critical infrastructure management. AI systems embedded in regulated products, such as medical devices, machinery, vehicles, and marine equipment, have until 2 August 2028. The deferral was driven by practical reality: most member states had not yet designated their national competent authorities, and the harmonised standards needed for conformity assessment were not finished.
The obligations themselves have not been softened. Companies in the categories above still face the full compliance regime of risk management systems, data governance, technical documentation, human oversight requirements, and conformity assessment. The runway is longer, but the destination has not changed. For anyone who read our earlier post on ISO/IEC 42001 as the management system framework for AI governance, the logic still holds. The standard remains the most structured path to demonstrating compliance, whether that deadline is 2026 or 2027.
SOURCE: Council of the European Union, 29 June 2026. https://www.consilium.europa.eu/en/press/press-releases/2026/05/07/artificial-intelligence-council-and-parliament-agree-to-simplify-and-streamline-rules/
Gibson Dunn, 27 May 2026. https://www.gibsondunn.com/eu-ai-act-omnibus-agreement-postponed-high-risk-deadlines-and-other-key-changes/
Technology.org, 17 July 2026. https://www.technology.org/2026/07/17/eu-ai-act-what-actually-applies-on-2-august-2026/
Picture: Sanket Mishra
