EU AI Act Article 50 Transparency Obligations — August 2, 2026: Chatbot Disclosures, AI-Generated Content Labels, Deepfake Notices Now Enforceable

The EU AI Act's Article 50 transparency obligations take effect on August 2, 2026 — 13 days from today — and were not deferred by the Digital Omnibus legislation signed July 8. The obligations that become enforceable on August 2 are: (1) users must be informed when they are interacting with an AI system, unless this is obvious from context; (2) AI-generated or AI-manipulated text published on matters of public interest must be disclosed as artificially generated; (3) deepfakes must be clearly labeled; and (4) providers of generative AI systems must support machine-readable marking of synthetic audio, image, video, or text outputs. For systems placed on the market before August 2, a grandfathering clause allows until December 2, 2026, for the machine-readable marking obligation — but chatbot disclosure and deepfake labeling requirements apply immediately. Penalties for Article 50 non-compliance and high-risk system violations: up to €15 million or 3% of global annual turnover. For legal tech operators and founders with European operations or European customers: the Article 50 compliance window is effectively closed — implementation should have been completed before today. The Digital Omnibus did move the high-risk system obligations from August 2026 to December 2, 2027 (Annex III stand-alone systems) and August 2, 2028 (Annex I product-embedded systems), giving vendors building AI into legal matter management, risk scoring, and e-discovery additional time on those heavier obligations — but the transparency layer is live.