August 2026 · Written on 13 November 2026. The month refers to the stated decision or effective date.
From 2 August 2026, AI Act transparency requirements apply to certain AI uses, including direct interaction with AI and obligations concerning synthetic content. Provider and deployer roles, the particular application and relevant exceptions require separate assessment.
Practical implications
Businesses should identify systems that interact directly with customers or employees and content that is generated or altered. The Commission discusses specific transitional issues for certain systems already placed on the market. These do not amount to a general postponement of all transparency obligations. Contractual responsibilities and technical marking should match actual publication processes.
Four practical examples
Illustrative scenarios, not accounts of client matters. The appropriate response depends on the documents, applicable law and procedural position.
A customer-service chatbot
The AI interaction notice is assessed where the interaction begins rather than being hidden solely in general terms.
A synthetic advertising video
The team checks the content type, the company's role and any disclosure required before publication.
An external AI platform
Contracts and technical functions are examined to determine which duties the provider performs and which remain with the user business.
An existing system
The business checks the specific transitional provision. A system's age does not automatically exempt it from every new requirement.
Documents and next steps
System inventory, provider contracts, user interfaces, content-production workflows and relevant deployment dates.
Keep the relevant contract or decision, correspondence and all service and event dates. Identify the outcome you want and any running deadline. For urgent matters, please also call the office.
Source: Official source and further reading. Editorial legal position: 13 November 2026.
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