Art. 50 transparency duties: which ones bind you, and what is due by 2 Dec 2026
Art. 50 is not one duty but three: the provider-side notice that a person is interacting with AI (50(1)), the provider-side machine-readable marking of synthetic content (50(2)), and the deployer-side disclosure for deepfakes and emotion recognition (50(3)-(5)). They bind different parties on different dates — the 2 Dec 2026 window covers only one of them.
The most common mistake: companies that merely deploy third-party generative tools assume they also have until 2 Dec 2026. Deployer duties have applied since 2 Aug 2026, with no transition period.
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