Written by: Haim Ravia, Dotan Hammer
On July 20, 2026, the European Commission published the final, non-legally binding guidelines on transparency obligations for providers and deployers of AI systems under Article 50 of the EU AI Act, ahead of the August 2, 2026 application date for the AI Act’s transparency rules (this date remains in place under the Digital Omnibus on AI). The guidelines were developed through an extensive consultation process: the Commission published an initial draft in March 2026, opened a public consultation, and published a revised draft in May 2026 before adopting the final version.
The transparency obligations under Article 50 apply to several categories of AI systems regardless of whether they are classified as high-risk. Providers of AI systems designed to interact directly with natural persons — such as chatbots — must ensure that individuals are informed that they are interacting with an AI system, unless this is obvious from the circumstances and context of use. Providers of AI systems that generate synthetic audio, image, video, or text content must ensure that the outputs are marked in a machine-readable format and are detectable as artificially generated or manipulated. Deployers of emotion recognition or biometric categorization systems must inform individuals who are exposed to the system of its operation and must process personal data in accordance with the GDPR.
The guidelines provide practical examples and detailed interpretations of each obligation, addressing questions such as what constitutes “obvious” context, the technical requirements for machine-readable marking (including watermarking and metadata embedding), and the specific disclosure obligations for deepfakes and AI-generated text published for the purpose of informing the public on matters of public interest. Notably, the guidelines clarify that deployers of AI systems that generate or manipulate text published for the purpose of informing the public on matters of public interest must disclose that the content has been artificially generated or manipulated — unless the content has undergone a process of human review or editorial control and a natural or legal person holds editorial responsibility for the publication.
Click here to read the European Commission’s final guidelines on AI transparency obligations.
