EU AI Act Transparency Obligations Live From August 2 — Enforcement Active, High-Risk Delay to December 2027
BY INSIDE PRACTICE · AUGUST 31, 2026 · 1 MIN READ
The EU AI Act's transparency obligations under Article 50 became enforceable from August 2, 2026: chatbots must disclose they are AI, AI-generated content requires machine-readable marking, deepfakes must be labeled, and biometric processing systems must notify individuals. Fines reach €15 million or 3% of global annual turnover for transparency violations, and the AI Office and national market surveillance authorities now hold active investigative and enforcement powers over general-purpose AI model providers. The Digital Omnibus amendment delayed the Annex III high-risk system obligations — covering employment, education, credit scoring, law enforcement — to December 2, 2027, and high-risk product-embedded systems (Annex I) to August 2, 2028. For legal tech operators with EU exposure: transparency compliance is not optional as of August 2; high-risk system conformity assessments remain on the 2027 runway, but documentation gaps on transparency are the first pattern regulators are flagging in enforcement.