EU AI Act Article 50: 2026 Compliance Guide for Non-EU Companies
2 August 2026 enforcement, the four obligations, the US state law mosaic, and a 6-step practical compliance checklist.
In short
Article 50 of the EU AI Act requires disclosure when people interact with AI systems and machine-readable marking of synthetic content, including deepfakes. New systems must comply from 2 August 2026; systems already on the market have until 2 December 2026 after the Digital Omnibus shortened the grace period.
- Cookietrace Privacy Engineering Team — Published 2026-05-20 · Updated 2026-08-18 · 10 min read
What Article 50 requires
Article 50 of the EU AI Act is the transparency article. People must know when they are interacting with an AI system, and synthetic content must be machine-readably marked. It applies to providers and deployers of chatbots, generated text, images, audio and video — including deepfakes used in marketing.
The four obligations
Disclose AI interaction at the start of any chatbot conversation, mark generated or manipulated content in a machine-readable format such as C2PA, disclose deepfakes clearly to the audience, and inform people when emotion recognition or biometric categorisation is used.
- Chatbot disclosure before the first exchange
- Machine-readable marking of synthetic media
- Visible deepfake labelling
- Notice for emotion recognition and biometric categorisation
Dates that matter
Article 50 obligations apply from 2 August 2026 for new systems. Systems already on the market get until 2 December 2026, after the Digital Omnibus package shortened the grace period from six months to three. Planning for the earlier date is the safer position for any site already running AI features.
How Cookietrace helps
The AI Disclosure Module adds a compliant disclosure layer to chat widgets and AI-generated pages, records the disclosure event in the same signed log used for cookie consent and exports it for audits — so AI transparency and cookie compliance are evidenced from one place.
Frequently asked questions
Article 50 of the EU AI Act requires disclosure when people interact with AI systems and machine-readable marking of synthetic content, including deepfakes. New systems must comply from 2 August 2026; systems already on the market have until 2 December 2026 after the Digital Omnibus shortened the grace period.
Does Article 50 apply to chatbots on my website?
Yes. Any chatbot must disclose that the visitor is interacting with an AI system before or at the start of the conversation, unless this is already obvious from the context.
What counts as synthetic content under Article 50?
AI-generated or manipulated text, images, audio and video, including deepfakes used in marketing, must carry machine-readable marking such as C2PA metadata, and deepfakes must also be labelled visibly for the audience.
When exactly must I comply?
New AI systems must comply from 2 August 2026. Systems already deployed before that date get until 2 December 2026, following the Digital Omnibus package's shortened three-month grace period.
Sources
Official sources cited in this guide.
Who should read it
Website owners, marketing teams and developers responsible for cookie consent, analytics tagging and privacy documentation.
Cookietrace
Written and reviewed by the Cookietrace Privacy Engineering Team. (10 min — regulations)