Guide · Article 50(2) · transition ends 2 Dec 2026

The 2 December 2026 deadline, explained

On 2 December 2026 the transition period for Article 50(2) of the EU AI Act ends: content generated by AI systems must carry machine-readable marking that says so. In our scan of 883 EU sites, 0.4% carry any such marking today. Almost everyone publishing AI-generated images, audio or video has this in front of them.

What the rule actually says

Article 50(2) requires providers of AI systems that generate synthetic audio, image, video or text to ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated. The marking must be effective, interoperable, robust and reliable as far as technically feasible. Routine assistive edits (colour correction, standard retouching) are carved out.

Systems already on the market before 2 August 2026 got a transition under the Digital Omnibus. That transition is what ends on 2 December 2026. The high-risk obligations everyone talks about were deferred to December 2027. This was not.

"I'm not a provider, I just publish the content"

Three reasons this still lands on your desk:

  1. Article 50(4) is yours already. Deployers must disclose deepfakes, and AI-generated text published to inform the public on matters of public interest, unless a named person takes editorial responsibility for it.
  2. Stripping metadata is the failure mode. Generators increasingly embed C2PA or IPTC provenance. Image pipelines (compression, resizing, CMS uploads) routinely strip it. Content that left the model compliant arrives on your site unmarked.
  3. Your suppliers' output is your surface. Agencies and freelancers deliver AI-generated assets without saying so. If it is published under your name, the questions come to you.

What counts as machine-readable

Two established mechanisms, both checkable by our scanner:

A visible "AI-generated" caption is good practice and helps with 50(4). But on its own it is not machine-readable marking.

What to do before the date

  1. Inventory. List where AI-generated media enters your publishing: product imagery, blog headers, social assets, supplier deliverables.
  2. Mark what you publish. Our free labelling tool writes IPTC digitalSourceType provenance into PNGs and JPEGs in your browser. Nothing is uploaded.
  3. Stop stripping. Check whether your CMS or image CDN preserves XMP/IPTC metadata on upload and resize; turn preservation on where it is optional.
  4. Put it in writing. A one-page labelling policy plus supplier terms that forbid removing provenance. The €49 Compliance Pack includes both, pre-filled from a scan of your site, with the dated evidence record.

Also on the clock

The interaction-disclosure duty in Article 50(1) has applied since 2 August 2026. Do you have to tell customers your chatbot is AI? Our own notice is public at /ai-transparency.