The Article 50(2) marking grace period ends 2 December 2026

Article 50 of the EU AI Act applies since 2 August 2026 — but one obligation comes with a short transitional window. For AI systems placed on the market before 2 August 2026, the machine-readable marking and detection duty of Article 50(2) applies only from 2 December 2026 (European Commission FAQ on Article 50; see also the Digital Omnibus, Regulation (EU) 2026/1744). That is the last Article 50 deadline of 2026 — and it is closer than it looks:

Who actually gets the extra time

The window is narrow. It covers you only if all three are true:

• you are a provider of an AI system (including a general-purpose AI system) generating synthetic audio, image, video or text;
• the system was placed on the market before 2 August 2026;
• the duty in question is the Article 50(2) machine-readable marking / detectability duty — nothing else.

Everything else applied on 2 August 2026 with no grace period: chatbot disclosure under 50(1), emotion-recognition and biometric categorisation disclosures under 50(3), and visible deep-fake / public-interest text labelling under 50(4). Systems placed on the market on or after 2 August 2026 must mark from day one. And content generated before 2 August 2026 does not need retroactive labelling, though the Commission encourages it where possible.

What to do with the four months

1. Inventory your generative outputs. List every surface where your product emits AI-generated audio, images, video or text that can reach EU users.
2. Pick a marking technique. For images, the C2PA Content Credentials standard is the most established machine-readable option — see our C2PA guide or sign images via one API call.
3. Follow the Code of Practice measures. The Commission-backed Code of Practice on Transparency of AI-generated Content (Section 1) is the recognised pathway for providers to implement and demonstrate Article 50(2) compliance.
4. Keep dated evidence. Marking that you cannot prove is marking that does not exist for an auditor. Run the free check to generate a dated obligations report, and see plans for continuous evidence packs.

After 2 December 2026

From that date the marking duty applies to all in-scope systems, old and new. Breaches of Article 50 obligations carry fines up to EUR 15 million or 3% of total worldwide annual turnover (Article 99(4)(g)). National market surveillance authorities enforce it — see who enforces the AI Act in each country.