WARRANTWhat the AI Office published on 10 June.
While the Digital Omnibus debate held everyone's attention on the high-risk stack, the AI Office published the Code of Practice on Transparency of AI-Generated Content on 10 June 2026. Six independent experts, appointed by the AI Office, drafted it through a multi-stakeholder process that ran from September 2025 with over 187 participants and three rounds of consultation. The code is voluntary. The obligations it maps are not.
The structure is two sections, and the section numbers matter because each maps to a different addressee and a different paragraph of Article 50. Section 1 addresses providers of generative AI systems under Article 50(2): the marking and detection of AI-generated or manipulated audio, image, video and text, including machine-readable solutions. Section 2 addresses deployers under Article 50(4): the labelling of deepfakes and of AI-generated text published to inform the public on matters of public interest. Annex I supplies an optional EU icon in three variants for the labelling duty.
The statutory hook is Article 50(7): the AI Office facilitates codes of practice for the detection and labelling obligations, and the Commission may approve a code by implementing act under Article 56(6) — or, if it finds the code inadequate, specify common rules itself under Article 98(2). The Commission and the AI Board will now assess the code's adequacy. The code does not replace the Commission's guidelines on Article 50, which land ahead of August.
Section 1 · the provider marking duty under Article 50(2).
The provider duty is machine-facing. The output of a generative system — audio, image, video or text — must carry a marking that software can read, so that the content is detectable as artificially generated downstream. General-purpose AI systems are named in scope. Section 1 of the code turns this into commitments on marking and detection that account for the type of content, the state of the art and relevant technical standards, with compliance proportionate to what is technically feasible.
The carve-outs sit in the same paragraph. The duty does not apply to the extent the system performs an assistive function for standard editing, does not substantially alter the input the deployer provided or its meaning, or where the use is authorised by law for the detection and prosecution of criminal offences. The marking question for a provider is binary and auditable: can a third party's tooling detect that this output was machine-generated?
Section 2 · the deployer disclosure duty under Article 50(4).
Article 50(4) carries two deployer duties. The first subparagraph covers deepfakes: a deployer of a system that generates or manipulates image, audio or video constituting a deep fake must disclose that the content was artificially generated or manipulated. The second covers text: where the system's text is published with the purpose of informing the public on matters of public interest, the deployer must disclose its origin. This is the paragraph that reaches newsrooms, public bodies, financial communications and any organisation whose published text shapes public understanding.
Section 2 of the code gives the practical layer: guidance on the design, placement and presentation of labels, disclaimers and icons, with specific regimes for artistic, creative, satirical and fictional work — where the statute itself limits disclosure to a manner that does not hamper the display or enjoyment of the work. For deployers who want a ready-made label, the Annex I icon exists precisely so the duty can be met consistently across the EU.
The exemption is a process claim.
The interesting clause in Article 50(4) is the second limb of the exemption. The text duty falls away where the content has undergone a process of human review or editorial control and a natural or legal person holds editorial responsibility for the publication. Both limbs must hold. A newsroom that routes AI-drafted copy through editorial review and publishes under a named editor does not have to label the text.
But read what the exemption actually is: a claim about a process. When the question arrives — from a market surveillance authority, or from opposing counsel — "a human reviewed it" has to exist as something you can show: who reviewed the content, and which natural or legal person held editorial responsibility at publication. An organisation that relies on the exemption without being able to evidence the review has not exited the obligation; it has converted a labelling duty into an evidentiary one.
For AI agents that draft or assemble published text at scale, the operational question is where that record lives. A per-publication record of the review step — who held it, when, against which version of the text — is the artifact that makes the exemption stand up. The shape of that record is the same shape regulators ask of agent records generally: see what records an AI agent must keep to satisfy a regulator.
The dates that did not move.
The May 2026 Digital Omnibus moved one set of dates and left another alone, and conflating the two is the most common error in current coverage. The deferral covers the Annex III high-risk stack — Article 12 record-keeping and Article 26 deployer duties among them — provisionally to 2 December 2027, with the European Parliament plenary vote expected around 7 July 2026. The full Omnibus picture is in the Omnibus, read against the record.
Article 50 sits in Chapter IV, not in the Annex III stack. Its obligations apply from 2 August 2026, undeferred. One softening exists: AI systems placed on the market before 2 August 2026 benefit from a transitional period until 2 December 2026. And before the application date arrives, the Commission will publish guidelines on the implementation of Article 50 — on scope, on which providers and deployers are covered, and on how the obligations apply in practice.
Penalties, and what signing buys.
Non-compliance with Article 50 sits under Article 99(4), which names the transparency obligations for providers and deployers directly: administrative fines of up to EUR 15 million or, for an undertaking, up to 3 percent of total worldwide annual turnover for the preceding financial year, whichever is higher. The same ceiling that applies to the record-keeping and deployer-duty breaches in the high-risk stack applies here — the difference is that this clock runs in 2026.
Adherence to the code is voluntary, and the code itself distinguishes the measures required for compliance with Article 50(2) and 50(4) from measures that are purely voluntary. What signature buys, per the AI Office, is a recognised route to demonstrate compliance: future enforcement will focus on monitoring adherence to the code, with predictability and legal certainty across the EU as the stated return. Providers and deployers sign by sending the Signatory Form to the AI Office, under the hand of someone with authority to bind the organisation.
Questions a compliance officer asks first.
Read the source directly.
- Code of Practice on Transparency of AI-Generated Content · European Commission FAQ (10 June 2026)
- Regulation (EU) 2024/1689 · EUR-Lex CELEX:32024R1689
- Article 50 transparency obligations · annotated text
- Article 99 administrative fines · annotated text
- The Digital Omnibus, read against the record · what was deferred and what was not
- Article 12, line by line · the record obligation in the deferred stack
- Article 26 deployer obligations · the deferred deployer duties
- The records an AI agent must keep · the artifact shape the exemption demands
Authored by Warrant Compliance, the regulatory-analysis function at Warrant. [email protected]. Editorial commentary on regulatory text. Not legal advice. The verbatim quotations of Article 50(2) and Article 50(4) reflect the official English-language text of Regulation (EU) 2024/1689 as published in the Official Journal of the European Union on 12 July 2024. Statements about the Code of Practice on Transparency of AI-Generated Content reflect the European Commission's FAQ as published at the date of this entry; the code itself was published 10 June 2026. The Annex III deferral to 2 December 2027 is provisional pending the European Parliament plenary vote and publication in the Official Journal.