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Compliance checklist

EU AI Act Article 50: what applies now, and the one deadline still ahead.

The AI Act's transparency rules have applied since 2 August 2026. The AI Omnibus gave a single duty more time: providers of generative AI systems placed on the market before that date have until 2 December 2026 to mark their output in a machine-readable way. Everything else is already in force. This checklist sorts the obligations by who owes them.

Humanums editorial·
Quick answer

Article 50 of the EU AI Act sets transparency duties for AI systems. Providers must tell people when they are talking to an AI and must mark synthetic audio, image, video and text in a machine-readable, detectable way. Deployers must disclose deepfakes, inform people exposed to emotion recognition or biometric categorisation, and label AI-generated text published to inform the public on matters of public interest, unless it has had human review or editorial control and someone holds editorial responsibility. The rules apply from 2 August 2026; only the marking duty for systems already on the market has a grace period, until 2 December 2026.

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Applies since 2 August 2026. The AI Omnibus did not postpone Article 50.

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Grace period to 2 December 2026 covers only the provider marking duty in Article 50(2), and only for systems placed on the market before 2 August 2026.

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Deployer duties, including labeling AI-generated text on matters of public interest, got no extra time.

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Fines for breaching these obligations reach up to €15 million or 3% of worldwide annual turnover, with proportionality for smaller companies.

Article 50 duties by role
DutyWho owes itDeadline
Tell people they are interacting with an AI systemProvidersIn force since 2 August 2026
Mark synthetic audio, image, video and text in a machine-readable, detectable wayProviders of generative AI2 August 2026 for new systems; 2 December 2026 for systems already on the market
Inform people exposed to emotion recognition or biometric categorisationDeployersIn force since 2 August 2026
Disclose deepfakes with clear, perceivable labelsDeployersIn force since 2 August 2026
Label AI-generated text published to inform the public on matters of public interestDeployers (unless human review and editorial responsibility apply)In force since 2 August 2026
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Step 1: Work out which role you are in

A provider develops an AI system, or has one developed, and places it on the market under its own name. A deployer uses an AI system in a professional capacity. A newsroom using a model to draft copy is a deployer. A software company shipping a feature that generates text for its customers is a provider of that feature, and its customers who publish the output are deployers.

Many organisations are both. Write down every place AI produces content in your products and your publishing, and next to each one, whether you built it or bought it.

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Step 2: Providers, the checklist

1. Chat and voice interfaces tell users they are dealing with an AI system, unless it is obvious from the context to a reasonably well-informed person.

2. Generated audio, images, video and text carry a machine-readable mark, and the output is detectable as artificially generated. The Commission describes an exemption for assistive features that perform standard editing or do not substantially alter the user's input.

3. If your generative system was on the market before 2 August 2026, the marking deadline is 2 December 2026. If you launched on or after 2 August, it already applies.

4. Consider the Commission's Code of Practice on Transparency of AI-generated Content, published in June 2026. It is voluntary, and following it is one way to demonstrate compliance.

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Step 3: Deployers, the checklist

1. Deepfakes (image, audio or video content that resembles real people, objects or events and would falsely appear authentic) are disclosed with clear labels. Evidently artistic, satirical or fictional work has lighter requirements.

2. People exposed to emotion recognition or biometric categorisation are told about it.

3. AI-generated or manipulated text published to inform the public on matters of public interest is labeled as such.

4. The text duty does not apply where the content has undergone human review or editorial control and a natural or legal person holds editorial responsibility for publishing it. If you rely on that exception, be able to show the review happened and who was responsible.

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Step 4: Document the text you did not generate

The labeling duty is about AI-generated text. Text a person wrote is outside it entirely. That sounds like the easy case, and it is, until a reader, a regulator or a platform's detector says otherwise. A detector's guess is not evidence either way, so the useful question is what record you hold.

This is where Humanums fits. A writer drafts in the Humanums editor or with the Chrome extension, and the piece is certified from the behavioral record of how it was written: typing rhythm, pauses, revisions. The certificate is signed, bound to the exact text, and verifiable at a public URL. It does not make AI-generated text compliant, and it is not a substitute for legal advice. It documents that a given piece was composed by a person.

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Step 5: Write the disclosure where one is needed

Labels should be clear and perceivable, at the latest when the reader first encounters the content. Specific beats vague: name what AI did, and who reviewed it. Our free disclosure statement generator produces that wording from a few choices, and the EU AI Act content labeling explainer on our blog covers the reasoning behind the rule.

Frequently asked

Quick answers.

Did the AI Omnibus delay Article 50?

No. The Omnibus mainly moved the high-risk system rules. Article 50 transparency duties have applied since 2 August 2026. The only extension is the four-month grace period on machine-readable marking for generative AI systems placed on the market before that date, running to 2 December 2026.

Do I have to label every blog post written with AI help?

The deployer duty covers AI-generated or manipulated text published to inform the public on matters of public interest, and it does not apply where the text had human review or editorial control and someone holds editorial responsibility. Many posts fall outside it. Platforms, employers and clients often have stricter rules of their own, so check those too.

Does a grammar checker count as AI-generated content?

The Commission describes an exemption from the provider marking duty for systems performing an assistive function for standard editing, or that do not substantially alter the input. Light spelling and grammar correction is usually understood to fall there. Substantial rewriting is a different matter.

What are the penalties?

According to the Commission, fines of up to €15 million or 3% of total worldwide annual turnover for companies, and up to €750,000 for EU institutions, with proportionality applied to SMEs. National market surveillance authorities enforce the rules.

Does a Humanums certificate make my content compliant?

It documents that a specific piece of text was written by a person, which is relevant because human-written text is outside the labeling duty. It does not cover AI-generated content, and it is not legal advice. For your specific obligations, consult a lawyer familiar with the AI Act.

Start certifying

Document what people wrote.

Certify human-written content with a signed record anyone can verify, so the question of labeling has an answer.