EU AI Act Article 50 Enforcement Live Since August 2; High-Risk Deadlines Deferred by Digital Omnibus

The EU AI Act's Article 50 transparency and disclosure obligations — requiring providers to clearly label AI-generated content and disclose when users are interacting with AI systems — became enforceable on August 2, 2026, alongside the general-purpose AI (GPAI) enforcement powers and the full penalty regime. However, the Digital Omnibus (Regulation EU 2026/1744), adopted July 24, deferred the highest-compliance-burden tier: high-risk AI obligations for stand-alone systems (Annex III, covering hiring, credit scoring, education, and critical infrastructure) are pushed to December 2, 2027, and high-risk AI embedded in regulated products to August 2028. For legal tech vendors selling into EU markets, Article 50 compliance is immediate and operational — disclosure obligations apply now to any AI system interacting with lawyers or generating content — while the more onerous conformity assessment process has more runway than the pre-Omnibus timeline implied.