On August 2 the transparency rules in Article 50 of the EU AI Act take effect. Most leaders read this year’s regulatory retreat as a reprieve, and for high-risk systems it was. June’s Omnibus pushed the first of those deadlines to December 2027. I read it that way here five weeks ago. Article 50 was never in that package, and this week the Commission closed the first signatory window for the code of practice that goes with it.
Why It Matters
Almost every headline about August 2 tells you to label your chatbot. Most of the weight falls on your vendor. Telling people they are talking to an AI, unless it is obvious, is a provider obligation. So is marking synthetic output so a machine can detect it. If you bought the system and run it as it came, both belong to your vendor. Put it into service under your own name and the Act may count you as the provider too. One obligation lands on you either way, as the deployer. When you publish text an AI wrote or reworked to inform people on a matter of public interest, you have to say so. The exception is the whole story. It drops away when a human has reviewed the content and someone holds editorial responsibility for it. The remedy is not a tool. It is a name.
The Decision
The question worth asking this week is where the boundary sits between marketing copy and text that informs people on a matter of public interest. It is genuinely unsettled. A reasonable CEO could go either way, scoping disclosure narrowly to what is plainly public-interest, or putting a named human behind everything published because that is the standard you wanted anyway.
What To Do This Week
- List every surface that publishes text in your name without a person reading it first: scheduled social, auto-generated blog, support macros.
- Write the name of whoever holds editorial responsibility next to each one. A blank is the finding.
- Ask your AI vendors, in writing, whether they signed the code of practice and whether their output carries machine-readable marking.
What Not To Do
Do not treat December 2 as breathing room. That grace period covers one thing only: marking the output of systems that were already on the market before August 2. The obligation that lands on you gets no grace at all. Do not buy a labeling product for a problem whose answer is a person’s name. And do not assume distance protects you, because the Act reaches deployers outside the Union whenever the output is used inside it.
Signal Boost
European Commission, Code of Practice on Transparency of AI-Generated Content - the Commission’s own FAQ on what Article 50 asks of providers versus deployers. Worth checking whether your vendors are on the signatory list.