EU AI Act Transparency Obligations Now Enforceable — KM Teams Must Audit AI Interactions on Client-Facing Matters

The EU AI Act's transparency obligations under Article 50 became enforceable on August 2, with immediate application to in-scope AI systems regardless of when they were placed on the market. For law firms operating in EU markets: any AI system that interacts directly with clients or generates content on matters of public interest must now disclose its AI nature and label AI-generated output with machine-readable marks where required. The obligations apply to the deployer — the law firm — not just the AI vendor, making AI disclosure a KM governance question: which AI interactions on client-facing matters generate content that requires labeling, and who is responsible for ensuring that labeling occurs? KM teams with visibility into AI usage logs and matter-level AI governance frameworks are positioned to answer this question; those without them are carrying undisclosed compliance exposure.