33 days to2 December 2026
Article 50 is in force. The grace period closes 2 December 2026.
Article 50(2) is the machine-readable marking duty, and it falls on the provider of a system that generates synthetic audio, image, video or text. If yours was on the EU market before 2 August 2026, it applies from 2 December 2026.
Dates verified 1 September 2026 against the Act implementation timeline and the European Commission. Orientation, not legal advice.
33days until 2 December 2026
2 Aug 2026122 day window2 December 2026
Counted on 2026-10-30, Europe/Brussels. Systems generating synthetic content, already on the EU market before 2 August 2026, have to carry machine-readable marking.
Five dates, drawn to scale, with today marked.
Article 50(2) transition window
Today, the fill on the axis and every status below are measured on 2026-10-30, Europe/Brussels.
- Applies
Article 50 transparency obligations apply
Enforcement powers start the same day. Article 50(1), 50(3), 50(4) and 50(5) bind from this date with no transition period at all.
- Next
Article 50(2) marking, for synthetic-content systems already on the market
The duty falls on providers of systems that generate synthetic audio, image, video or text and were on the EU market before 2 August 2026. It does not reach systems that only classify, rank or predict, and it carries an express carve-out for an assistive function for standard editing that does not substantially alter the input or its semantics.
- Pending
Older general-purpose AI models
Set by Article 111(3) of the AI Act itself rather than by the Digital Omnibus: models placed on the market before 2 August 2025 have until this date. The duty is the model provider's, not the duty of a firm building on one.
- Pending
Annex III high-risk, use-based
Deferred from 2 August 2026 by Regulation (EU) 2026/1744, the Digital Omnibus on AI, published in the Official Journal on 24 July 2026 and in force since 27 July 2026.
- Pending
Annex I high-risk, product-regulated
AI inside products already governed by EU product law. Deferred from 2 August 2027 by the same instrument, and the last date on the current schedule.
SourceRegulation (EU) 2024/1689 as amended by the Digital Omnibus on AI. Today, the fill and every status are measured on the counting day above.
Does this apply to us?
5of 5
gated by one scope test
Placed on the EU market, put into service, or its output used, in the EU.
4of 5
then tested one at a time
Article 50(1) to 50(4) are judged separately, and the duty holder changes between them.
1of 5
carries a transition date
50(2), 2 December 2026, and only for systems already on the EU market before 2 August 2026.
0of 5
need a conformity assessment
Article 50 is transparency and disclosure, not the high-risk conformity regime.
Tested first, for 50(1) to 50(5)
Is the system placed on the market, put into service, or its output used, in the EU? A confirmed no engages none of them. An unsettled answer lets none be firmer than “may be engaged”.
| Paragraph | Duty holder | Applies from |
|---|---|---|
| Article 50(1)Telling people they are talking to an AIProvider duty. Applies from 2 August 2026, with no transition period. | Provider | 2 August 2026, with no transition period. |
| Article 50(2)Marking synthetic output so a machine can detect itOnly systems generating synthetic audio, image, video or text. Not one that only classifies, ranks or predicts, nor one that only assists with standard editing or does not substantially alter what the user gave it.Provider duty. Applies from 2 August 2026, with a transition running to 2 December 2026 for systems already on the EU market before that date. | Provider | 2 August 2026, with a transition running to 2 December 2026 for systems already on the EU market before that date. |
| Article 50(3)Telling people they are subject to emotion or biometric analysisDeployer duty. Applies from 2 August 2026, with no transition period. | Deployer | 2 August 2026, with no transition period. |
| Article 50(4)Disclosing deepfakes, and generated text on matters of public interestDeployer duty. Applies from 2 August 2026, with no transition period. | Deployer | 2 August 2026, with no transition period. |
| Article 50(5)How and when the information has to be givenNot a separate test: it applies whenever one of 50(1) to 50(4) does.Provider and deployer. Applies from 2 August 2026, with no transition period. | Provider and deployer | 2 August 2026, with no transition period. |
SourceRegulation (EU) 2024/1689, Article 50(1) to 50(5), with the 50(2) transition in Article 111(4) as added by the Digital Omnibus on AI; read at EUR-Lex on 14 September 2026. Article 50(6) and 50(7) put no duty on a provider or deployer, so they are not rows. Each row is printed from the rules behind the free Article 50 check; the scope test and the 50(2) and 50(5) notes are ours, checked against those rules when the page is built.
Where it does not apply, we say so. Telling a US-only firm with no EU exposure that it is out of scope beats manufacturing urgency.
Test one of your own systems: the free Article 50 check runs the same rules on your answers.
What exactly must we do?
Four streams, in this order. None of them is a conformity assessment.
- 01
Inventory
Every AI system: its purpose, who it faces, whether it generates content, which model sits underneath, and a named owner.
- 02
Classification
Which paragraphs each system engages, and why, written down with a date and an author. Without those it is an opinion, not evidence.
- 03
Disclosure
User-facing wording, in the interface, at the moment it is relevant. A paragraph buried in a policy PDF is not a disclosure.
- 04
Evidence
A dated log of what you decided, on what basis, what shipped and what changed since: the record an authority would ask for.
What happens if we do not?
We do not publish fine figures on this page. Penalty exposure depends on the provision engaged and the member state enforcing it, and a number quoted out of that context is the kind of thing your counsel will correct in front of your board.
Enforcement powers exist as of 2 August 2026
Article 50 began to apply on the same date, so there has never been a window in which the duty existed and nobody could act on it. The figure below is who can.
SourceRegulation (EU) 2024/1689. The AI Office and member-state authorities have held enforcement powers since 2 August 2026, the day Article 50 began to apply. A notified body belongs to the high-risk conformity route, which applies from 2 December 2027 for Annex III and 2 August 2028 for Annex I; Article 50 transparency asks for no conformity assessment.
The 10 that decide it, then everything else.
Every answer on this page, open or closed, is the same string this page puts in its structured data, so a person and an answer engine read identical text. You can check that by viewing source.
30questions answered on this page
10 open, below20 in the long tail
Article 50 is already in force. Have we missed it?
Not necessarily.
Article 50 has applied since 2 August 2026, but what runs to 2 December 2026 is Article 50(2) alone: machine-readable marking, for providers of synthetic-content systems already on the EU market before August. Article 50(1), 50(3), 50(4) and 50(5) applied from 2 August 2026 with no transition period at all, so for those the question is not whether a deadline was missed. It is whether the disclosure is in the interface today, and whether anyone wrote down why.
Does the EU AI Act apply to a US company with no EU office?
Reach follows the market rather than your registered address.
If you place an AI system on the EU market, put it into service there, or its output is used in the EU, treat it as in scope until counsel qualified in the relevant jurisdiction says otherwise. If you have no EU users, no EU customers and no EU-facing output, it does not reach you today. That is an answer we give on the first call rather than selling an assessment nobody needs.
Does Article 50 reach a system only our own employees use?
Nothing in Article 50 turns on whether the people on the other end are your staff or the public.
Article 3(4) carves out one thing only, use in the course of a personal, non-professional activity, and an employer running a system across its own workforce is not that. Employees are natural persons, so an internal assistant that talks to them can engage Article 50(1) exactly as a customer-facing one does. Internal tools are the easiest thing to leave off an inventory, because nobody thinks of a rota generator or a helpdesk bot as a product, which is where a written inventory of AI systems earns its cost. One caution this page does not settle: whether a system that infers the emotions of people at work may lawfully be operated at all is governed by parts of the Act outside Article 50, and that question comes before any question about disclosing it. Take it to counsel first.
Do we have to complete the full high-risk conformity process this year?
No.
Regulation (EU) 2026/1744, the Digital Omnibus on AI, deferred Annex III high-risk obligations to 2 December 2027 and Annex I to 2 August 2028. It was published in the Official Journal on 24 July 2026 and has been in force since 27 July 2026. Anyone selling you a high-risk conformity program on a 2026 deadline is quoting a superseded timeline, and your counsel will notice.
What is the difference between Article 50 transparency and the high-risk regime?
They are different obligations on different schedules, and this page keeps them apart because conflating them in front of your own counsel costs more credibility than saying nothing.
Article 50 is transparency and disclosure: tell a person they are dealing with an AI, mark synthetic output so a machine can detect it, disclose a deepfake, and do all of it clearly and in time. It has applied since 2 August 2026, with 2 December 2026 as the one transition date, and it asks for no conformity assessment and no notified body. The high-risk regime is a separate classification carrying its own documentation, risk management and conformity duties, and it applies from 2 December 2027 for Annex III and 2 August 2028 for Annex I. A system can be inside Article 50 and outside the high-risk classification entirely, which is the ordinary case for a support assistant or a content generator and the reason a transparency engagement is a week rather than a program.
Does Article 50(2) reach a classifier, a ranker or a recommender?
No.
Article 50(2) is about marking synthetic output so it is machine-detectable as artificially generated. A system that classifies, ranks, scores or predicts without producing audio, image, video or text has nothing to mark, so the paragraph does not reach it on either date. Coverage that presents 2 December 2026 as a deadline for every AI system a firm runs has skipped this line of the Article.
We use a third-party model. Is this the vendor's problem?
It depends on your role for that system, and the role is settled system by system.
The provider develops the system, or has it developed, and places it on the market or puts it into service under its own name or trademark; Article 50(1) and 50(2) fall on it. The deployer is whoever uses the system under its own authority, other than for personal, non-professional use; 50(3) and 50(4) fall on it. Article 50(5) falls on whichever of the two holds the duty it attaches to. Build a system and run it yourself and you are both, so both sets apply. Build on a vendor's model and ship the result under your own name, and you are its provider.
What does evidence actually mean here?
Five artifacts: the inventory of AI systems, the classification decision for each one, the written reasoning behind that decision, the disclosure wording you shipped and where it appears, and the dated log of what changed since.
None of it is exotic work. What makes it hard is that it is nobody's job until somebody is named. The same five turn up under different names in enterprise diligence, so it is not spent once.
Can MetaMinds certify us as compliant?
No.
The EU AI Act is a regulation, and its obligations sit with the organizations placing and deploying systems, not with a consultant's certificate. For ISO/IEC 42001 we do gap assessment, readiness, control design and evidence preparation; the certificate comes from an accredited certification body after an external audit, and a SOC 2 report from a licensed CPA firm, never from us.
What do we get for the EU AI Act readiness assessment?
EU AI Act readiness assessment, T2-01 in the published catalog: 1 week, $4,900, with a $900 deposit reserving the week and the balance invoiced against delivery.
It produces the inventory of AI systems in scope, a written classification per system with the reasoning recorded, the transparency gaps ranked by exposure against 2 December 2026, the disclosure wording you are missing, and an evidence structure your counsel and your enterprise buyers can both work from. Where a system needs nothing, the report says so in its own section.
20 more, on scope, on each paragraph, and on the dates
What is the one scope test that gates every paragraph of Article 50?
Whether the system is placed on the market, put into service, or its output used, in the European Union. A confirmed no leaves Article 50(1) to 50(5) all not engaged. An unsettled answer is not a no: it caps every paragraph at may be engaged, because no verdict can be firmer than the scope question it rests on. Settle that one first. It is usually a contract and traffic question rather than a legal one.
What does Article 50(1) require, and who owes it?
Article 50(1) is a design obligation and it sits on the provider. A system intended to interact directly with natural persons has to be designed and developed so that the people concerned are informed they are dealing with an AI system, unless that is obvious to a reasonably well informed and observant person taking the circumstances and the context of use into account. Two consequences follow from it being a design duty. It is discharged in the product rather than in a policy document, because the Act attaches the obligation to how the system is built. And the carve-out is a judgment about your own interface, which a regulator would read against the least attentive plausible user rather than against the team that shipped it, so the safe position is to write the notice and keep the reasoning. Binding since 2 August 2026, with no transition window.
What does machine-readable marking mean under Article 50(2)?
Article 50(2) requires the provider of a system that generates synthetic audio, image, video or text to mark that output so a machine can detect it as artificially generated or manipulated. The duty is about the output, not about a policy page: a notice a person can read is not a marking a detector can read. It applied from 2 August 2026, and systems already on the EU market before that date carry a transition to 2 December 2026. On what counts as adequate marking there is now something to build against: the Commission published a Code of Practice on Transparency of AI-generated Content on 10 June 2026. It is voluntary and it is not a harmonised standard, so it carries no presumption of conformity, but with no harmonised standard cited for the AI Act it is the most concrete statement of expectations that exists, and adhering to it is treated as one route to demonstrating compliance rather than the only one.
Does Article 50(2) reach a grammar checker, a reformatter or a tone editor?
Usually not. Article 50(2) carries an express carve-out where the system performs an assistive function for standard editing, or does not substantially alter the input data provided by the deployer or its semantics. Two cautions before relying on it. Substantially is doing the work in that sentence, and a feature that began as tone correction and has since learned to draft whole paragraphs has probably left the carve-out without anyone deciding that it should. Write down what the system does today, with the date, because that record is the thing you would show.
Our synthetic-content system launched after 2 August 2026. Does the December date apply?
No, and it is the simpler case. The transition covers systems already on the EU market before 2 August 2026. For a system placed on the market or put into service on or after that date, the Article 50(2) marking duty applied from the day it was placed, so there is no window left to run out. Changelogs, release notes and announcements date this better than memory does, and the date is worth writing down now rather than reconstructing later.
Our system talks to people directly. Which part of Article 50 does that engage?
Article 50(1). The systems it catches in practice are customer support assistants, voice agents, intake bots, automated callers and anything else where a person is on the other end of an exchange and may not know what they are talking to. The duty belongs to the provider of the system rather than to every business that switches one on, and it has bound that provider since 2 August 2026: the December date people quote at you is the Article 50(2) marking transition and does not reach this paragraph at all. Where a person would plainly know what they are dealing with, the Act carves the case out, but that is a call about your interface, so record who made it and on what date. A chat window that names itself an AI assistant in its opening line and a voice agent that answers in a human-sounding greeting are not the same case.
Our system generates content that reaches an audience. Which paragraphs engage?
Two of them, and they fall on different parties. Article 50(2) is the provider's duty to mark synthetic audio, image, video or text so a machine can detect it as artificially generated. Article 50(4) is the deployer's duty to disclose deepfake image, audio or video, and generated text published to inform the public on matters of public interest. Marketing copy generation, synthetic voice, image editing at scale and generated summaries published under your name are the common cases, and a retrieval system that composes an answer generates text.
Our system infers emotions or categorizes people from biometric data. What does that trigger?
Article 50(3), the duty to inform the people exposed to an emotion recognition or biometric categorisation system. It sits with the deployer, not the provider, and it applied from 2 August 2026 with no transition period. It is easy to miss in a product that does this as one feature among many rather than as its headline function, which is where an inventory of AI systems earns its cost. The spelling of categorisation is the Act's own, in the English text of Article 50(3). One boundary worth naming, because this page does not settle it: a disclosure duty assumes the system may be operated in the first place, and where the people exposed are at work or in an education setting, whether it may be run at all is governed by parts of the Act outside Article 50. That is the prior question, and it goes to counsel before any notice gets written.
Who has to disclose a deepfake, the provider or the deployer?
The deployer. The first subparagraph of Article 50(4) requires the deployer of a system that generates or manipulates image, audio or video content constituting a deep fake to disclose that it has been artificially generated or manipulated. Article 3(60) defines a deep fake as AI-generated or manipulated image, audio or video content resembling existing persons, objects, places, entities or events that would falsely appear to a person to be authentic. If you are only the provider it is your customer's obligation, and worth documenting for them.
Does the artistic or satirical case switch the Article 50(4) duty off?
No, and this is the case most often reported as an exemption. Where the content forms part of an evidently artistic, creative, satirical or fictional work, the obligation is reduced rather than removed: the existence of generated content still has to be disclosed, in a manner that does not hamper the display or enjoyment of the work. A credit is usually enough. Silence is not.
Does the editorial-responsibility carve-out cover synthetic video?
No. That carve-out belongs to the text limb of Article 50(4) only, the second subparagraph, which covers generated text published to inform the public on matters of public interest and does not apply where the content has undergone human review and a person holds editorial responsibility for the publication. It does not reach deepfake image, audio or video. A broadcaster with full editorial control over a synthetic video still owes the disclosure on that limb.
When and how does the disclosure have to be given?
Article 50(5) governs the manner and the timing of whatever the paragraphs above require. The information has to be given clearly and distinguishably, at the latest at the time of the first interaction or exposure, and it has to conform to the applicable accessibility requirements. It binds the provider and the deployer, whichever of them holds the duty it attaches to. It is the paragraph most often satisfied on paper and failed in the interface.
Why does this page stop at Article 50(5)? What about 50(6) and 50(7)?
Article 50 runs to 50(7). Article 50(6) says that 50(1) to 50(4) leave Chapter III and other transparency law untouched, and 50(7) covers codes of practice and was rewritten by the Digital Omnibus on AI. Neither puts a duty on a provider or a deployer, which is why this page lists 50(1) to 50(5) and names that range rather than calling them all five paragraphs of the Article. Read at EUR-Lex on 14 September 2026.
Which instrument moved the high-risk dates, and when did it take effect?
Regulation (EU) 2026/1744, the Digital Omnibus on AI, adopted on 8 July 2026, amending Regulation (EU) 2024/1689. The mechanism is worth knowing if you ever check this against the text yourself: the new schedule is not written into the Omnibus as a free-standing date, it is written by replacing point (c) of Article 113 of the AI Act, the provision that says when Chapter III, the high-risk chapter, starts to apply. So the operative dates are read out of the amended Act rather than out of the amending regulation, which is why a search of the Omnibus alone can leave you thinking the dates moved less than they did. The Article 50 transparency dates were not touched by it. A great deal of guidance was written before July 2026 and still states the superseded schedule as current, so check the publication date on anything you are relying on.
Is there a separate deadline for general-purpose AI models already on the market?
Yes, 2 August 2027, and it is set by Article 111(3) of the AI Act itself rather than by the Digital Omnibus: providers of general-purpose AI models placed on the market before 2 August 2025 have until that date to comply. If you build on someone else's model that obligation is theirs, not yours, and the date is a useful thing to put on the agenda of your next vendor review.
Is there a free way to check one of our own systems?
Yes. The Article 50 check at metaminds.store/tools/article-50 runs the same rules this page is built from, over eight questions about one system, in the browser, with no email required. It is engineering triage rather than a compliance determination and it says so: every question carries an explicit I would have to check option, an unsettled scope answer caps everything below it, and two of its five verdicts, not engaged and cannot tell, lead to no paid work at all.
What does the free Article 50 check actually return?
A separate verdict for each paragraph, Article 50(1) through 50(5), rather than one score for the system. The five possible verdicts are engaged, may be engaged, applies in reduced form, not engaged on these answers, and cannot tell from these answers, and each one is printed with the reasoning that produced it and the duty holder it falls on. Three of the five leave something worth working on and two of them do not, which is why a run can end with the tool telling you there is nothing to buy.
Does ISO/IEC 42001 certification make us compliant with the EU AI Act?
No. ISO/IEC 42001 is a management-system standard and the EU AI Act is a regulation. The certificate is evidence of a governed process; it is not a determination that a given system meets Article 50, and no auditor issues one about the Regulation. The two are complementary and neither substitutes for the other. MetaMinds runs ISO/IEC 42001 gap assessment, readiness, control design and evidence preparation; the certificate itself is issued by an accredited certification body after an external audit.
Do the harmonised standards and notified bodies exist yet?
That is a question about machinery rather than about obligations, and the honest answer changes month to month, so MetaMinds keeps a dated register of it at metaminds.store/eu-ai-act-status instead of asserting a state here: harmonised standards, notified bodies and national authorities, each checked at source with the date it was checked. The obligations in Article 50 apply whether or not the machinery around them is finished.
What are the fines, and what is our exposure?
MetaMinds does not publish a fine figure on this page. Penalty exposure under the AI Act depends on the provision engaged and on the member state enforcing it, so a number quoted out of that context is the kind of thing your counsel corrects in front of your board. What is worth stating plainly instead: the AI Office and member-state authorities have held enforcement powers under the Act since 2 August 2026, the same day Article 50 began to apply.
EU AI Act readiness assessment
1 week, fixed scope. Where a system needs nothing, the report says so.
33 days to2 December 2026
Not legal advice. We describe obligations and the evidence that closes them; anything with legal effect should be reviewed by qualified counsel.
$4,900
$900 deposit reserves the week. Balance invoiced against delivery.
- Inventory of AI systems in scope
- Written classification, with the reasoning recorded
- Transparency gaps ranked by exposure
- Disclosure wording you are missing
- Evidence structure counsel and buyers can both use
Deeper problem than transparency? The security, grounding and agent governance assessments run $5,900 to $7,900.
Fixed price · 1 week