Commission turns Article 50 transparency duties into an operating checklist

On October 22, 2026, the European Commission published guidelines explaining the AI Act’s Article 50 transparency obligations for providers and deployers of certain AI systems. The duties, which have applied since August 2, cover disclosure when people interact with AI, machine-readable marking of synthetic content, and labelling of deepfakes and specified AI-generated publications. Law firms and legal departments should map client-facing assistants, automated intake, generated marketing content and internal tools that produce external-facing material to the relevant provider or deployer role. Procurement terms should also require vendors to document marking capabilities, preserve compliance evidence and notify customers when product changes affect Article 50 controls.