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The EU Code of Practice on Transparency of AI-Generated Content is a voluntary way for businesses to implement and demonstrate certain transparency duties under Article 50 of the EU AI Act. The duties themselves are not voluntary: they have applied since 2 August 2026. The European Commission and the AI Board found the code adequate for the relevant obligations, but signing it does not by itself prove compliance.
What is the Code of Practice on Transparency of AI-Generated Content?
Published on 10 June 2026, the code is an EU-wide framework for putting into practice certain Article 50 transparency requirements. It is organized into two sections: one for providers of AI systems and one for deployers that use them. An organization can have both roles and may sign both sections.
The code was developed with more than 187 participants from industry, academia, civil society, rightsholders, Member States and external observers, according to the European Commission. That drafting group is distinct from the organizations that later signed it.
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Does the code impose additional obligations beyond the AI Act?
No. The code is voluntary and does not create duties beyond Article 50. However, the applicable Article 50 transparency requirements are legal obligations. The Commission concluded on 8 July 2026 that the code adequately covers Articles 50(2), (4) and (5); the AI Board adopted its adequacy assessment on 9 July. The Commission describes adherence as a recognized means of demonstrating compliance, but cautions that “Adherence to the code does not constitute conclusive evidence of compliance with these obligations.” (Commission adequacy assessment.)
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Signatories may rely on the code’s measures as a recognized compliance route. A business that does not sign still has to meet any duties that apply to it. It can use an alternative approach, but must be able to show that its measures are adequate; authorities assess alternatives individually. Keeping a documented gap analysis against the code can help explain how the alternative meets the law.
The Commission’s code page states: “Even though adherence to the code is voluntary, the transparency requirements under article 50 of the AI Act are legal obligations.” The code does not replace the AI Act or the Commission’s Article 50 guidelines, which clarify definitions, scope, examples and exemptions.
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Who is eligible to sign up to the code?
Providers and deployers can sign the section relevant to their role. Providers build or supply AI systems and undertake measures such as marking and detection. Deployers use AI systems and may have disclosure duties for specified output. Businesses providing tools, services or infrastructure for content marking, provenance, watermarking or detection are also identified in the Commission’s signing FAQ as eligible participants.
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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsSigning is by section: signatories cannot select only individual commitments within a section. The initial-signatory submission deadline was 27 July 2026 at 18:00 CEST, but the Commission’s signing FAQ says providers and deployers may in principle sign later by submitting the form. The Commission reported about 190 companies and organizations as signatories by the end of July 2026; this is a dated count, not a live total.
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What measures does the provider section cover?
The provider section addresses marking and detecting AI-generated or manipulated audio, images, video and text. It calls for machine-readable marks and detection methods that are effective, interoperable, robust and reliable as far as technically feasible. Implementation should account for the content type, technical limits, costs and state of the art; the framework does not establish a universal detection-accuracy figure or endorse a particular tool.
For a provider, the practical question is whether its marking and detection approach works across the relevant media and can be relied on under realistic technical constraints. The evidence should explain the chosen measures, their limitations and how the design reflects feasibility and interoperability.
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When do deployers need to label AI-generated content?
The deployer section focuses on two categories: deepfakes, and AI-generated or manipulated text published to inform the public on matters of public interest. It does not mean that every AI-generated text must be labeled. Whether a duty applies depends on the output, how it is used and the relevant legal conditions and exceptions.
The code provides guidance on labels, disclaimers and icons, including the presentation of creative, satirical, fictional or analogous works. It also addresses situations involving human review and editorial responsibility. Businesses should read these provisions alongside the Commission’s Article 50 guidelines rather than treating “AI-generated” as the only test.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How do I label AI-generated content?
- Identify your role. Decide whether your organization is acting as a provider, a deployer, or both for the relevant system and content.
- Classify the material or interaction. Determine whether the issue is generated or manipulated media, a deepfake, public-interest text, or a direct interaction with an AI system. Check the Article 50 guidelines for scope and applicable exceptions.
- Choose the relevant measures. Providers should assess machine-readable marking and detection across applicable media. Deployers should determine whether a visible label, disclaimer or icon is required and how it should be presented.
- Account for context and feasibility. Consider content type, technical limitations, interoperability, cost and state of the art. For deployer disclosures, consider creative or satirical context and any relevant human review or editorial responsibility.
- Keep evidence. Record the role analysis, decision about whether disclosure is required, measures selected, known limitations and the basis for concluding that the approach meets the applicable duty.
- Decide whether to sign. If signing, submit the relevant section. If using another route, document why the alternative measures are adequate and be prepared to explain them to the relevant market-surveillance authority.
The code includes an optional EU icon in three variants. It is a design option within the framework, not a substitute for determining whether a legal disclosure duty applies or for implementing the underlying measures.
What are the consequences of not signing the code?
Not signing does not remove an applicable Article 50 duty. A non-signatory may use other adequate measures, but should be able to substantiate that approach because authorities assess alternatives individually. Conversely, signing is not a guarantee: the organization remains accountable for actually meeting its obligations.
Article 50 duties began applying on 2 August 2026. Commission materials also describe a transitional period until 2 December 2026 for certain systems placed on the market before 2 August. That transition is limited to specified pre-existing systems; it should not be assumed to apply to every transparency duty or output. Check the Commission’s current guidance against the particular system and circumstances.
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How should a business choose its implementation route?
Start with the legal question, not the choice of tool. The Commission materials do not establish a universal ranking of vendors or technologies. A useful internal review compares:
- Role: provider, deployer or both.
- Covered activity: generated or manipulated media, deepfakes, public-interest text or a direct AI interaction.
- Route: adherence to the relevant code section or an alternative set of measures.
- Technical performance: effectiveness and interoperability across audio, images, video and text where relevant.
- Feasibility: technical constraints, cost and the state of the art.
- Evidence: documentation that can be provided to the relevant market-surveillance authority.
The code is therefore useful as an implementation framework and a reference point for documentation, not as a blanket exemption or a shortcut around determining which legal duties apply.
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