EU AI Act Article 50 Takes Effect August 2 — Chatbot Disclosure, AI Content Labeling, and GPAI Enforcement Now 11 Days Away

The EU AI Act's Article 50 transparency obligations take effect on August 2, 2026 — eleven days from today — alongside the Commission's enforcement powers over general-purpose AI (GPAI) models. The Digital Omnibus on AI (signed July 8, awaiting Official Journal publication) deferred the high-risk regime but explicitly left Article 50 and GPAI enforcement on the original timeline. The obligations that become enforceable on August 2: providers of AI systems intended to interact with natural persons must inform users they are interacting with an AI system (unless objectively obvious from context); providers of AI systems generating synthetic audio, image, video, or text content must mark outputs in a machine-readable format; deployers of deepfake content must clearly and visibly disclose the artificial nature; deployers of AI-generated text on matters of public interest must disclose it as AI-generated. For systems already on the market before August 2, the machine-readable marking obligation runs until December 2, 2026 (a six-month phase-in for the technical implementation); chatbot disclosure and deepfake labeling apply immediately to all systems from August 2. High-risk Annex III stand-alone systems: December 2, 2027. Annex I product-embedded systems: August 2, 2028. Penalties: up to €15 million or 3% of global annual turnover. For law firms and legal departments with EU operations, European clients, or legal tech vendors deployed in the EU: Article 50 compliance is not a 2027 horizon item — it is an August 2 operational requirement. The practical question is whether every client-facing AI system, every AI-assisted document generation workflow touching EU counterparties, and every AI research tool used by lawyers in the EU has been assessed for disclosure compliance.