AI disclosure · EU · updated

The code of practice on transparency of AI-generated content: where it stands

The code exists because Article 50(7) of the AI Act asks for it: “The AI Office shall encourage and facilitate the drawing up of codes of practice at Union level to facilitate the effective implementation of the obligations regarding the detection and labelling of artificially generated or manipulated content.” (AI Act, Art. 50(7), applies from 2 August 2026). The resulting code was published on 10 June 2026; on 8 July 2026 the Commission concluded that it adequately covers Articles 50(2), (4) and (5), and the AI Board adopted its own adequacy assessment the next day.

What the Commission's opinion says it means

“Providers and deployers of AI systems falling within the scope of the transparency obligations laid down in Articles 50(2), (4) and (5) AI Act may rely on the Code as the EU-wide recognised instrument that is considered adequate to ensure compliance with their respective obligations, regardless of their place of establishment, operation or competent market surveillance authority, while recognising that adherence to the Code does not constitute conclusive evidence of compliance with these obligations.”
Commission Opinion C(2026) 4839 final, point (52) · Commission Opinion on the assessment of the code, C(2026) 4839 final, 8 July 2026 · read 8 October 2026
“Even though adherence to the code is voluntary, the transparency requirements under article 50 of the AI Act are legal obligations.”
European Commission, Code of Practice on Transparency of AI-generated Content (policy page, updated 31 July 2026) · Code of Practice on Transparency of AI-generated Content, published 10 June 2026 · read 8 October 2026

Where it stands, by date

DateWhat happenedSource
17 Dec 2025First draft publishedCommission
3 Mar 2026Second draft publishedCommission
8 May 2026Draft Article 50 guidelines published for consultationCommission
10 Jun 2026Final code publishedCommission
8 Jul 2026Commission Opinion C(2026) 4839 final: the code is adequateCommission
9 Jul 2026AI Board adopts its adequacy assessmentCommission
20 Jul 2026Guidelines on Article 50 adopted, C(2026) 5054 finalCommission
end of Jul 2026About 190 signatories, by the Commission's countCommission
2 Aug 2026Article 50 appliesAI Act, Art. 113
2 Dec 2026Marking deadline for systems already on the marketAI Act, Art. 111(4)
2 Feb 2027Signatories' interoperable detection solution dueCode, Measure 3.4(c)
“Signatories will implement an interoperability solution for their detection mechanisms by 2 February 2027”
Code of Practice, Measure 3.4(c) · Code of Practice on Transparency of AI-generated Content, published 10 June 2026 · read 8 October 2026

Article 50(7) also lets the Commission approve a code by implementing act. As of 8 October 2026 we found none for this code on the Commission's pages; the adequacy finding is an opinion. The AI Office says it will review the code at least every two years.

What the code asks of providers (Section 1)

“Signatories will implement a multi-layered marking approach to ensure that the outputs of their generative AI systems are marked with at least two layers of machine-readable marking, as specified in Sub-measures 1.1.1 and 1.1.2 below.”
Code of Practice, Section 1, Measure 1.1 · Code of Practice on Transparency of AI-generated Content, published 10 June 2026 · read 8 October 2026
“All recorded information will be digitally signed and time-stamped (on systems where time information is available) in a secure and tamper-evident manner.”
Code of Practice, Sub-measure 1.1.1 (digitally signed metadata) · Code of Practice on Transparency of AI-generated Content, published 10 June 2026 · read 8 October 2026
“Signatories will ensure that AI-generated or manipulated content is marked with an imperceptible watermark, with the exception of very short text.”
Code of Practice, Sub-measure 1.1.2 (imperceptible watermarking) · Code of Practice on Transparency of AI-generated Content, published 10 June 2026 · read 8 October 2026

Signing the code is done by sending the Commission's signatory form; providers and deployers who do not sign have to show that their own measures are adequate. Article 50(2) marking and Article 50(4) labelling have their own pages.

$ npx --allow-git=root github:agentwares/agent-disclosure output generated.png

Shows which of the code's two marking layers a file visibly carries: signed metadata (a C2PA manifest) and whether the manifest declares a watermark. The watermark itself needs the generator's detector.

A signed readiness report

The free checks print everything they find. The Article 50 readiness report ($49, one-time, no account) is the same checks for up to 10 URLs and 25 artefacts, dated and hash-signed, as PDF and JSON, to keep or hand over.

Keep a dated record of every check, and of every disclosure and marking you ship

okgate keeps every tool call your agents make in a hash-chained audit log with daily Merkle roots on a public page: 90 days on Pro ($99/month), 365 days with a compliance export on Team ($299/month).

A record of your disclosure and marking checks, kept the same way, is not built yet. I want that record

The texts, each read on 8 October 2026