European Union: European Commission opened consultation on draft guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of AI Act

On 8 May 2026, the European Commission opened a consultation on the draft guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of Regulation (EU) 2024/1689 (the AI Act) until 3 June 2026. The draft guidelines outline the four transparency obligations in Article 50 of the AI Act. Article 50(1) requires providers of AI systems intended to interact directly with natural persons to design and develop such systems so that natural persons are informed they are interacting with an AI system, with exceptions for obvious interaction or systems authorised by law for law enforcement purposes. Article 50(2) requires providers of AI systems generating synthetic audio, image, video, or text content to implement technical solutions for machine-readable marking and detection that are effective, interoperable, robust, and reliable as far as technically feasible, taking into account the state of the art. Examples include watermarks, metadata identifications, cryptographic methods, logging methods and fingerprints. Article 50(3) requires deployers of emotion recognition systems and biometric categorisation systems to inform exposed natural persons of the operation of the system. Article 50(4) requires deployers to label deep fakes and AI-generated or manipulated text published to inform the public on matters of public interest, with attenuated obligations for artistic, creative, satirical or fictional works where disclosure must not hamper display or enjoyment of the work. Article 50(5) requires information under Article 50(1) to (4) to be provided in a clear and distinguishable manner at the latest at the time of first interaction or exposure and to conform to applicable accessibility requirements. The grandfathering rule under Article 111(2) AI Act for high-risk AI systems does not apply to the transparency obligations in Article 50. Under Article 113 AI Act, Article 50 applies from 2 August 2026. Providers and deployers that do not comply with the applicable transparency obligations in Article 50 AI Act may be fined up to EUR 15 million or, if the offender is an undertaking, up to 3% of its total worldwide annual turnover for the preceding financial year, whichever is higher.