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The European Commission Publishes Guidelines on the Transparency Obligations under the AI Act

The European Commission (“Commission”) has published its Guidelines (“Guidelines”) on the implementation of the transparency obligations applicable to certain artificial intelligence systems under Article 50 of Regulation (EU) 2024/1689 (“AI Act”) on 20 July 2026.

According to the Guidelines:

  • Providers of AI systems intended to interact directly with natural persons must ensure that individuals are informed that they are interacting with an AI system, unless the artificial nature of the interaction is obvious or a specific law-enforcement exception applies.
  • Providers of AI systems generating or manipulating synthetic image, audio, video or text content must ensure that such outputs are marked in a machine-readable format that is effective, interoperable, robust and reliable, enabling their detection as AI-generated or manipulated.
  • Deployers of emotion recognition or biometric categorisation systems must inform the natural persons exposed to such systems about their operation.
  • Deployers of AI systems generating or manipulating deep-fake content must clearly disclose that the content has been artificially generated or manipulated. A specific disclosure regime applies to artistic, creative, satirical, fictional or similar works.
  • AI-generated or manipulated text published for the purpose of informing the public on matters of public interest must also be disclosed as such, unless the content has undergone human review or editorial control and editorial responsibility is assumed.
  • The relevant information must be provided in a clear, distinguishable and accessible manner, at the latest at the time of the first interaction with or exposure to the AI system. Disclosures included solely in terms and conditions, technical documentation or non-perceivable machine-readable markings will generally not be sufficient.
  • The applicable obligations may apply cumulatively where a single AI system or its outputs fall within more than one category. Accordingly, the same entity may qualify as both a provider and a deployer depending on its role in the development and use of the system.

The transparency obligations under Article 50 of the AI Act will become applicable on 2 August 2026, and non-compliance may result in administrative fines.

You can access the full text of the Guidelines here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

 

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