The AI Act clock: guidelines and a code of practice on transparency

On 20 July 2026, shortly before the 2 August date of application, the European Commission adopted its final guidelines on implementing Article 50 of the AI Act. These documents are not legally binding, but they carry weight as interpretation, and they spell out what is expected of providers and deployers. Providers must disclose direct interaction — as with chatbots — and apply machine-readable markings to synthetic content. Deployers, meaning those who put the systems to use, must instead declare the use of deepfakes, the synthetic origin of texts on matters of public interest that no human has reviewed, and the use of emotion recognition or biometric categorisation technologies.

The picture is completed by the code of practice on the transparency of AI-generated content, published by the AI Office on 10 June 2026 and tied to Article 50(2), (4) and (5). It points to digitally signed metadata, imperceptible watermarking, fingerprinting and logging mechanisms as marking techniques, alongside standardised icons. Worth noting: standard editing functions, such as plain spell-checking, are explicitly exempted from the marking obligations, which draws a boundary around how far the rule reaches.

Sign-up forms for appearing on the list of initial signatories had to reach the AI Office by 27 July 2026 at 18:00 CEST; the Commission will publish the list before 2 August. In the meantime, on 24 July 2026, in an official blog post signed by Karen Massin (Head of Government Affairs and Public Policy for EU institutions), Google announced that it will sign the code. The company says it is accelerating adoption of the C2PA standard and using SynthID technology, citing work with Apple, Eleven Labs, Kakao, NVIDIA and OpenAI on interoperable watermarking. On technical timing, a legal analysis by NicFab notes that the Digital Omnibus regulation pushes the machine-readable marking obligation back to 2 December 2026 for systems already placed on the market; that point still needs checking against the Digital Omnibus text as published in the Official Journal, which we could not consult as a primary source.

Some practical uncertainties remain. Beyond Google's announcement, the full make-up of the signatory group is unknown until the official publication. Neither the scale of the penalties nor the length of the document — put at 51 pages by outside analyses — has been verified against a primary source. And it remains to be seen how national authorities, AgID and ACN in Italy, will turn these obligations into practice from 2 August 2026.

— Olya