What has applied since 2 August 2026 — and for whom is 2 December 2026 a transition deadline?

Short answer

One date, not two: Article 50 has applied since 2 August 2026 — paragraph 2, the machine-readable marker, included. 2 December 2026 is not a general grace period. It is a transition rule for providers of AI systems placed on the market before 2 August 2026, and it covers paragraph 2 only.

Why that is

The general date of application of the regulation is 2 August 2026 (Article 113). Chapter IV, which contains Article 50, is not carved out there — paragraphs 1, 2, 3 and 4 have applied since that day. 2 December 2026 comes from a different provision: Article 111(4), inserted by Regulation (EU) 2026/1744, the AI Omnibus package. That transition rule is limited in three ways at once. It addresses providers of AI systems. It covers only systems placed on the market before 2 August 2026. And it moves paragraph 2 alone — neither the in-dialogue disclosure under paragraph 1 nor the visible marking under paragraph 4. Where any of the three does not hold, paragraph 2 has applied since 2 August 2026 with no transition period at all. Which of these fits a given case — provider role or not, legacy system or not — is deliberately not something we answer: it turns on contracts and on the role in which the software is supplied, and neither is measurable from the outside of a website. That is why our check P3 carries 02.08.2026 in the finding: the date the duty starts, not the end of an exception that may not apply at all.

This is measured in check point P3 — Machine-readable labeling of images (Art. 50 Abs. 2).

What this means in practice

Do not treat December as your start date unless it is settled that all three limits of the transition rule fit your situation. In practice: the chat disclosure under paragraph 1 is due regardless and takes minutes — one edited greeting message in the admin area of your chat tool. Machine-readable marking hangs off your entire image chain: generation, editing, CMS, CDN. Because several systems are involved, rebuilding it takes far longer than writing one sentence. If someone advises you to wait until December, the next question is which of the three limits they are relying on.

Check it on your own page

None of this changes what is visible from outside. The check measures the current state of your site — chat disclosure, image metadata, findable transparency notice. Alongside it, finding P3 names 02.08.2026 as the date from which the marking duty exists.

Related questions

• Did the Digital Omnibus delay the AI disclosure rules?
• How do I mark AI images in a machine-readable way?
• Does the EU AI disclosure duty apply to small websites and sole traders?