EU AI Act Article 50 in Force: Transparency Obligations Apply to KM-Adjacent AI Deployments

EU AI Act Article 50 transparency obligations — enforceable from August 2, 2026 — apply directly to legal tech tools used by law firms and in-house teams with EU market exposure: AI systems interacting directly with people must disclose their artificial nature at the point of interaction; generative AI outputs must be machine-readable marked as artificially generated (transitional period to December 2, 2026 for systems placed on market before August 2); and AI-generated text on matters of public interest must be disclosed as artificially generated unless meaningful human editorial review has occurred. The provider/deployer distinction is critical for KM teams that have configured, white-labelled, or substantially modified third-party AI systems — those teams may be requalified as providers, triggering conformity, documentation, and penalty exposure (up to EUR 15M or 3% of worldwide turnover). For KM directors, the compliance action is immediate documentation: an AI systems register covering all tools deployed, Article 50 transparency evidence for each, and supplier contracts with clearly allocated obligations. The EU AI Act's Annex III high-risk obligations — covering employment, credit, essential services, and justice — do not take effect until December 2, 2027, providing runway to prepare the deeper compliance infrastructure.