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TransparencyTimeline July 16, 2026

Legacy generative systems get until December 2 to carry the mark

New generative output must be marked from August 2; pre-existing systems get a short transition.

ANALYSIS — EDITORIAL, NOT THE LEGAL RECORD

The Article 50 marking duty for AI-generated content phases in on two dates. Newly placed generative systems must mark their synthetic output from 2 August 2026, alongside the wider transparency obligations.

Systems already on the market get a short transition. The marking requirement for pre-existing, legacy generative systems applies from 2 December 2026, a window that the Omnibus trimmed from six months to three.

The practical message for providers with a deployed generative product is that the transition is not long, and it is not optional. By early December the machine-readable marking must be in place across the existing estate, not only on newly shipped versions.

Sources: Art. 50 · Art. 113 · verified 2026-07-16
Analysis is original writing by the euaicompliant desk. Not legal advice — the binding text is on EUR-Lex.
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