The EU Started Enforcing the AI Act's Transparency Rules on August 2
1The EU Now Requires an AI System to Disclose That It Is AI
A chatbot operating in the EU has to tell people they are talking to software. The chatbot disclosure duty and three others took effect on August 2, 2026, when the European Commission's AI Office and national authorities began enforcing Article 50 of the AI Act, the section covering transparency.
Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use.
EU AI Act, Article 50(1)
Article 50 adds three more duties, which do not all fall on the same party. Providers of systems generating synthetic audio, image, video or text must mark the output in a machine-readable format so it can be detected as artificially generated. Deployers running emotion recognition or biometric categorization must inform the people exposed to it, and must disclose deepfakes as artificially generated. The same applies to AI-written text published to inform the public on matters of public interest, unless it went through human review or editorial control and a person or company holds editorial responsibility for publishing it.
2Whose Name Is on the System Decides Which Duties Apply
Which duties a company owes turns on the Act's two roles. A provider develops a system, or has one developed, and then places it on the market or puts it into service under its own name. A deployer uses one under its own authority. Whichever role applies, the notice has to reach people at the first interaction or exposure at the latest, in a form they can tell apart from human output.
Internal use is not an exemption. What falls outside the interaction duty is a system running only in the background, machine to machine, with no direct contact with people. A chatbot employees talk to has that contact and owes the disclosure. Emotion recognition aimed at staff is a separate matter again, because Article 5 prohibits inferring emotions in the workplace outside narrow medical and safety cases.
Grace period for marking obligation until December 2026 for generative AI systems placed on the market before 2 August 2026 (Article 50(2) AI Act, amended by AI Omnibus).
European Commission, Quick Facts: Transparency Rules for AI Systems
Those providers must comply from 2 December 2026, while anything placed on the market from August 2 onward has to comply immediately. Enforcement runs mainly through national market surveillance authorities, with the AI Office covering the systems under its supervision and the European Data Protection Supervisor covering the EU's own institutions. Article 99 caps the fine at 15 million euros or 3% of worldwide annual turnover, whichever is higher. Small and medium companies, including startups, pay the lower of the two.
Source: European Commission, "Quick Facts: Transparency Rules for AI Systems" and "Commission starts enforcing AI Act rules and new transparency requirements on 2 August", July 31, 2026.