2 December 2026: the Article 50(2) machine-readable marking deadline

The only Article 50 transition ends on 2 December 2026. Not legal advice.

Article 50 has applied since 2 August 2026

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The only Article 50 transition ends on 2 December 2026. Not legal advice.

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The only Article 50 transition ends on 2 December 2026. Not legal advice.

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AI-generated. No human review. Not legal advice. Every finding cites the Article 50 paragraph it relies on.

Reviewed: October 25, 2026

What the transition covers

Regulation (EU) 2026/1744 (the "Digital Omnibus" amendment) gives providers of generative AI systems (text, image, audio, video) placed on the market before 2 August 2026 until 2 December 2026 to comply with Article 50(2): outputs marked in a machine-readable format and detectable as AI-generated or manipulated.

Not covered:

  • Systems first placed on the market on or after 2 August 2026: mark from the start.
  • Chatbot disclosure (50(1)), emotion-recognition notices (50(3)), and deepfake and certain public-interest text disclosures (50(4), first and second subparagraphs) have applied since 2 August 2026.

Checklist before 2 December

  1. List every feature that outputs synthetic text, images, audio or video to people.
  2. Confirm you are the provider: you develop the system or ship it under your name. Building on a third-party model doesn't automatically shift the duty to the model vendor.
  3. Check exclusions: assistive standard editing, output that doesn't substantially alter the input, source code, machine-to-machine output.
  4. Choose marking that is effective, interoperable, robust and reliable as far as technically feasible. Section 1 of the (voluntary) Code of Practice on Transparency of AI-generated Content sets out marking measures.
  5. Ask your model vendor what marking it already applies.
  6. Record what you implemented and when.

Penalties: up to EUR 15M or 3% of turnover (higher); SMEs: lower (Art. 99(4)(g), 99(6)).

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FAQ

Does 2 December 2026 delay chatbot disclosure?

No. Article 50(1) has applied since 2 August 2026.

Does signing the Code of Practice give extra time?

No. It's a voluntary way to demonstrate compliance with 50(2), (4) and (5).

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