Article 50 of the AI Act requires AI-generated content to be marked and labelled. The European Commission has now published a second draft of the Code of Practice giving that obligation operational shape, following stakeholder feedback gathered in January 2026. Comments on the second draft close on 30 March 2026, the finalised Code is expected in early June 2026, and the transparency rules themselves become applicable on 2 August 2026.
Two audiences, one obligation
The draft is organised in two sections: one addressed to providers of generative systems, the other to deployers. That distinction carries more weight than it first appears. A faculty, a clinic or a firm that licenses a generation tool is a deployer, and carries duties of its own that are not discharged by the vendor’s compliance. Anyone planning to adopt such a tool should read the deployer section before signing anything.
Why a document tool is not obviously outside
Marking is easy to picture for synthetic images and much harder to picture for text. A clause-assembly tool that selects and stitches pre-approved wording is doing something categorically different from a model that drafts new language. Whether the second sits inside Article 50 turns on how the system works, not on which sector it is sold into. That is exactly why the Code matters: it is where an abstract duty becomes a concrete instruction about what to embed, where, and in what format.
In the same weeks
The 2026 International AI Safety Report was launched at the New Delhi AI Impact Summit, chaired by Yoshua Bengio and written by more than a hundred independent experts from over thirty countries. Separately, the AI Standards Lab counted more than 750 European Parliament amendments to the Digital Omnibus requiring assessment, and ten member states – Germany, France, Italy, Spain and Poland among them – asked the Commission to clarify how the AI Act interacts with EU machinery law.
For teaching purposes the useful date is 2 August 2026. Until then, marking is a design question. After it, it is a legal one.
Drawn from The EU AI Act Newsletter #97, 9 March 2026.