EU AI Act Article 50 Requires Disclosure of AI Interactions — KM Must Address Legal AI Transparency Obligations

EU AI Act Article 50 transparency obligations became enforceable on August 2, 2026, requiring providers and deployers to ensure users are informed when they interact with AI systems and that AI-generated content on matters of public interest carries machine-readable marks. DLA Piper's August 6 analysis flagged an additional risk directly relevant to legal AI deployments: firms that fine-tune, customize, or rebrand third-party AI tools may qualify as providers under the Act, triggering more onerous conformity obligations than simple deployer status. For KM directors in firms with EU market exposure, Article 50 compliance is now a documentation and policy issue, not a future planning item: interaction disclosure must be built into AI workflow design, and the firm's KM team is typically the function that owns the workflow-level specifications where disclosure logic is embedded. The Digital Omnibus deferred high-risk system obligations to December 2027, but transparency duties apply now.