Article 50 before 2 August: a working checklist

Article 50 of the EU AI Act applies from 2 August 2026

Companion to "Article 50 of the EU AI Act applies from 2 August 2026". Engineering guidance, not legal advice.

Five days out, the useful question is not what the article says. It is which of these you can answer today.

1. Establish your role, system by system

Article 50 assigns duties to providers and to deployers, and most organisations are both.

List every AI system you develop and place on the EU market or put into service under your own name. These are your provider obligations: 50(1) and 50(2). List every AI system you use under your own authority, including third-party ones. These are your deployer obligations: 50(3) and 50(4). Confirm coverage for systems operated outside the EU. If the output is used in the EU, the Act reaches it. Do not exclude open-source components. There is no open-source exemption in Article 50.

2. Provider duties

50(1), interaction disclosure

Every system that holds a genuine two-way exchange with a person tells them they are dealing with AI. The notice appears at the start of the first interaction, in a clear and distinguishable form, meeting accessibility requirements. Any reliance on the "obvious" exception is written down with the reasoning. It is to be read restrictively. Systems that only run machine-to-machine or in the background are excluded, and you can show which ones those are.

50(2), machine-readable marking

Generative outputs carry signed, time-stamped, tamper-evident provenance metadata where the format supports it. C2PA is the practical answer. An imperceptible watermark is embedded in the content itself, robust to compression, cropping, scaling and format conversion. Free-form text above roughly 200 tokens is watermarked. The signed-manifest alternative did not survive into the final Code of Practice. A detection route exists for the public: a published specification, a tool, or a free API. Existing marks applied upstream are preserved rather than stripped, and you do not ship circumvention tooling. Excluded output types are identified: short character sequences, source code, machine-to-machine output, closed-loop industrial and product-development use. Assistive standard-editing features are assessed against the Guidelines examples rather than assumed to be out of scope.

3. Deployer duties

50(3), emotion recognition and biometric categorisation

People exposed to these systems are informed that they are operating, in real time and in ex-post use alike.

50(4), deepfakes and public-interest text

Deepfake output carries a label a person can see or hear, at first exposure at the latest, with no special tools or deliberate action needed to reveal it. You are not relying on the provider's machine-readable mark to satisfy this. It does not. Artistic, satirical or fictional work still discloses, in a way that does not spoil the work. AI-generated text published to inform the public on matters of public interest is labelled, unless a documented human review or editorial control process applies and someone holds editorial responsibility. That review is recorded per publication, not asserted as a general policy. Spell-checking and formatting checks do not qualify. Consider the EU icons. They are optional and do not establish compliance on their own.

4. Evidence

The obligation is to comply. The practical problem is proving you complied on a given date, for a given user, in a given country.

Disclosure wording is versioned, with effective dates. The version in force is recorded per request, not only in a policy document. Disclosure and marking settings are scoped per project and per jurisdiction, so a regulated assistant and an internal tool cannot inherit each other's configuration by accident. The record is queryable by user, country, system and date. You can produce, for any past request, what was disclosed and which rule caused it.

5. Dates

Date	What happens
2 August 2026	Article 50 applies. All four obligations, all systems in scope, regardless of when they shipped
2 August 2026	Fines become available: up to 15 million euros or 3% of worldwide annual turnover
2 December 2026	The 50(2) marking duty for systems already on the market before 2 August, per the Digital Omnibus provisional agreement, pending formal adoption

Content generated before 2 August needs no retroactive marking. For public-interest text, the date that counts is publication, not generation.

6. Decide on the Code of Practice

Read it as a technical specification whether or not you sign. If you sign, implement its measures, including placement and presentation rules for labels. If you do not sign, write down how you demonstrate compliance instead. Non-signatories should expect more requests for information.

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Sources for every point above are listed in the main article. The Commission's Article 50 FAQ is the shortest authoritative starting point.