This is an operator checklist, not a legal opinion and not a finding that your use is covered. The European Commission’s AI Act Service Desk says Article 50 transparency rules started to apply on August 2, 2026. It also says that for certain generative systems already placed on the market before that date, the Article 50(2) machine-readable marking duty has a transition that ends December 2, 2026. The Council’s timeline records the high-risk delay separately: December 2, 2027 and August 2, 2028. Do not let a vendor use the high-risk date to answer a transparency question.
The dates
| Date | What the public timeline says |
|---|---|
| August 2, 2026 | Transparency rules apply. Enforcement for those rules is underway. |
| December 2, 2026 | Marking transition ends for certain generative systems already on the market. New prohibitions on non-consensual intimate imagery and child sexual abuse material generation also apply. |
| December 2, 2027 | Stand-alone high-risk duties. Not the transparency date. |
| August 2, 2028 | High-risk duties for systems embedded in regulated products. |
The ask
- Is a person told they are interacting with an AI system, where the Act requires it? Ask for the screen, not the policy.
- If the system generates synthetic audio, image, video, or text, what machine-readable mark do you apply, and as of which date?
- Was this system on the market before August 2, 2026? If yes, the vendor should be able to say whether they are inside the December 2, 2026 transition.
- Which article and annex are you relying on when you say “not until 2027”?
FAQ
We are a US company. Does this matter?
It matters if the vendor, the user, or the customer is in the EU, or if the contract pushes EU duties onto you. The checklist is the question list. Counsel decides whether you are a provider or a deployer.
Where is the law?
Regulation (EU) 2024/1689 on EUR-Lex, read with the Commission timeline that includes later amendments. Do not brief from a blog’s date if it disagrees with those two.