Enforcement date
Article 50 transparency obligations apply from 2 August 2026. Systems already on the market get a grace period until 2 December 2026.
Article 50 transparency obligations apply from August 2, 2026. Most of what you’ve heard about watermarking requirements is wrong — or at least aimed at the wrong party. Here’s what actually applies to your agency, and what Solvgent handles for you.
Article 50 transparency obligations apply from 2 August 2026. Systems already on the market get a grace period until 2 December 2026.
Deployers (agencies using AI for content) must disclose deepfakes and AI text on matters of public interest. Routine marketing captions are not covered.
AI model providers (Anthropic, OpenAI) must watermark outputs at the model level. This is not the deployer’s responsibility.
If you publish AI-generated images or video that appreciably resemble real persons, you must disclose. Abstract illustrations, product mockups, and generic stock-style images are typically exempt.
AI-generated text on civic, news, or public affairs matters must be disclosed. Marketing copy and product descriptions are out of scope.
Creative, satirical, and fictional content is exempt. The EU Act recognizes that artistic expression does not carry the same disclosure obligations as news or public communications.
Model providers (Anthropic, OpenAI) must implement machine-readable watermarks per Article 50(2). That is their legal obligation, not yours.
Solvgent operates under enterprise terms with both providers — they cannot train on your data AND they handle the watermarking.
Nothing your agency needs to build or maintain.
No. Article 50’s watermarking obligation falls on AI model providers (Anthropic, OpenAI), not on deployers like agencies. Your responsibility is disclosure of deepfakes and public-interest AI text.
No. Article 50(4) covers text “published with the purpose of informing the public on matters of public interest” — civic, news, public affairs. Standard brand marketing, product descriptions, and social captions are not in scope.
If you generate images that appreciably resemble real persons (deepfakes per Article 3(60)), you must disclose. Abstract illustrations, product mockups, and generic stock-style images are typically exempt.
August 2, 2026 for new systems. Systems already on the market before that date get until December 2, 2026 per the May 7 Omnibus agreement.
Solvgent attaches C2PA-aligned ai_generated metadata to every AI-produced asset regardless of legal requirement. Caption-level disclosure language is a one-toggle default. We help you stay ahead of the law without a compliance project.