EU AI Act Article 50 Transparency Obligations in Force — August 2, 2026

EU AI Act Article 50 transparency obligations became enforceable on August 2, 2026 — creating a mandatory compliance layer for every legal tech product deployed in or accessible to EU markets. The obligations cover four categories: AI systems interacting directly with people must disclose their artificial nature at the point of interaction (clear, plain language, not buried in terms of service); 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); emotion recognition and biometric categorisation systems must inform all exposed individuals; 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: legal tech companies that fine-tune, substantially modify, white-label, or rebrand third-party AI systems may be requalified as providers, triggering full conformity, documentation, and penalty exposure (up to EUR 15M or 3% of worldwide turnover). Annex III high-risk obligations — covering employment, credit, essential services, biometrics, law enforcement, and justice — do not take effect until December 2, 2027, giving operators runway to prepare. For legal tech operators with EU customers, the immediate compliance action is documentation: an AI systems register, Article 50 transparency evidence, supplier contracts with allocated obligations, and compliance files that can be produced to national market surveillance authorities on demand.