Deployer obligations under the AI Act: Implications for employers from 2 August 2026

At a glance

• From 2 August 2026, Article 50 of the EU AI Act (AI Act) imposes mandatory transparency obligations on providers and deployers of AI systems.
• To support compliance, the European Commission has published guidance explaining the scope of the transparency obligations, available exemptions, and practical compliance steps.
• A voluntary Code of Practice on Transparency of AI-Generated Content offers a structured compliance pathway.

On 31 July 2026, the European Commission confirmed that from 2 August 2026, it will begin enforcing the AI Act’s rules and new transparency requirements under Article 50.

Article 50 distinguishes between providers and deployers. Article 50(2) AI Act imposes a technical marking obligation primarily on providers of AI systems, rather than on employers acting as deployers. Article 50(4) is of direct relevance to employers, as it requires the labelling of deepfakes and AI-generated publications intended to inform the public on matters of public interest, where no human editorial control has been exercised.

To support enforcement, the AI Office has launched several tools for individuals and businesses to report suspected non-compliance with the AI Act.

The Commission published detailed Guidelines on transparency obligations for providers and deployers of AI systems. These non-binding guidelines are intended to assist providers, deployers and national authorities in interpreting and applying Article 50.

The Commission also published the Code of Practice on Transparency of AI-Generated Content (Code). The Code has a section dedicated to deployers, which contains rules for labelling deepfakes and AI-generated or manipulated text published on matters of public. Deployers commit to clear, visible disclosure to persons exposed to such content.

The Code is voluntary to sign. The underlying Article 50 transparency obligations remain mandatory legal requirements regardless of whether an organisation signs the Code. After a positive assessment by the Commission and the European AI Board, signatories may rely on the Code’s measures to demonstrate compliance with the AI Act’s labelling and detection rules.

AI systems already placed on the market before 2 August 2026 benefit from a transitional period. They have until 2 December 2026 to comply with the Article 50(2) obligations.