Is 2 December 2026 the EU AI Act transparency deadline?

Only for one duty in one case: machine-readable marking under Article 50(2), for generative systems placed on the market before 2 August 2026 (Omnibus Regulation 2026/1744). Everything else in Article 50 has applied since 2 August 2026.

Do new AI systems get the marking grace period?

No. Systems placed on the market on or after 2 August 2026 must mark immediately — the transition covers only pre-existing systems.

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2 December 2026: exactly what the AI marking transition covers — and what it never covered

Current to 26 August 2026 · updates land in the changelog.

The most misquoted date in AI-transparency compliance. 2 December 2026 is not “when Article 50 starts”. Article 50 has applied since 2 August 2026 — a date set by Article 113 of the AI Act itself. The December date is one specific transition, created by the Digital Omnibus (Regulation (EU) 2026/1744, in the OJ 24 July 2026, in force 27 July 2026).

The transition's exact scope

Situation	Rule
Generative system placed on the market before 2 Aug 2026	The 50(2) machine-readable marking duty applies from 2 December 2026
Generative system placed on or after 2 Aug 2026	Marking applies immediately — no runway
50(1) interaction disclosure · 50(3) emotion/biometric information · 50(4) deepfake and text disclosure	No grace at all — live since 2 Aug 2026

That is the entire effect on Article 50. The Omnibus's high-risk postponements (Annex III to December 2027, Annex I to August 2028) are separate provisions that do not touch transparency.

Why the date exists

Marking is the one duty requiring engineering across a shipped fleet — retrofitting provenance pipelines into systems already on the market. The legislator gave that, and only that, four months. Disclosure lines and labels were judged deployable by August; the adoption record bears out that reading.

Using the runway, if you have it

Four months is enough for the real work — choosing the marking stack, wiring it, and survival-testing it across delivery paths — if it starts as an engineering project with a deadline rather than a legal memo. Systems shipped after August have no runway, so new launches need marking at day one; and none of this waits on the visible-disclosure duties, which are already live.

Related guides

Quick answers

Is 2 December 2026 the EU AI Act transparency deadline?: Only for one duty in one case: machine-readable marking under Article 50(2), for generative systems placed on the market before 2 August 2026 (Omnibus Regulation 2026/1744). Everything else in Article 50 has applied since 2 August 2026.
Do new AI systems get the marking grace period?: No. Systems placed on the market on or after 2 August 2026 must mark immediately — the transition covers only pre-existing systems.

Ship the disclosures before enforcement finds the gap.

The AI Act Article 50 Kit: the disclosure copy library (English + 中文), the marking implementation guide with survival-test protocol, deepfake and text-labeling walkthroughs, obviousness and scope memos, the evidence log, the Code of Practice accession path — built from the regulation and the final guidelines, with pinpoint citations.

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General information only — not legal advice, and no clearance opinions. Sources are Regulation (EU) 2024/1689 (Articles 50 and 99), Regulation (EU) 2026/1744, the Commission's final Article 50 guidelines of 20 July 2026 (non-binding) and our audited kit research. Marking-technology status changes fast: treat vendor announcements as live only once verified. © 2026 Kilde.

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