AI Act: Code of Practice published — D-46 for your AI notices

Summary — On 10 June 2026, the European Commission published a Code of Practice for marking and labelling AI‑generated content. From 2 August 2026, the transparency obligations under Article 50 apply across the EU. Signing is open, with a public list of signatories expected in July 2026.

The facts

The Commission released the Code of Practice on the marking and labelling of AI‑generated content on 10 June 2026. The voluntary document provides practical steps (labels, icons, use cases) to help providers and deployers comply with transparency obligations effective from 2 August 2026. Signing is open and a public list is due in July 2026. This milestone complements the Commission’s draft guidelines (8 May 2026) and the Digital Omnibus package, which sets 2 December 2026 as the deadline for machine‑readable labelling of content already in production before 2 August 2026.

These announcements directly affect organisations that publish content or interfaces involving conversational AI systems, emotion recognition, or producing “deepfakes”. See official sources (Commission, AI Office, Council of the EU) at the end of this article.

Legal framework and basis

• Regulation (EU) 2024/1689 (AI Act), Article 50 — Clear and visible information when a person interacts with an AI system (50(1)), when emotion recognition or biometric categorisation systems are used (50(3)), and disclosure/labelling of artificially generated or manipulated content (“deepfakes”) (50(4)). For background, refer to the AI Act Article 50 overview.
• Code of Practice (10/06/2026) — Good practices for marking/labelling, including EU icons, and a public adhesion process.
• Digital Omnibus (07/05/2026) — Confirms applicability from 2 August 2026 and introduces a window until 2 December 2026 for machine‑readable labelling of content already circulating before 2 August 2026.

What this changes for Luxembourg businesses

• Immediate exposure — Any entity deploying a chatbot/assistant, publishing AI‑generated/manipulated content (images, audio, video, public‑interest text), or experimenting with emotion recognition is subject to transparency obligations as of 2 August 2026. Supervisory authorities may request evidence (screenshots, banners, logs, procedures). This is particularly relevant to organisations established in Luxembourg.
• Risk — Visible non‑compliance (missing warning, inadequate labelling) and inability to demonstrate implementation. The Code offers an operational blueprint; public signing in July 2026 will create a market signal.
• Specific timeline — If you already distribute synthetic content before 2 August, the “machine‑readable” component benefits from a window until 2 December 2026; other obligations (user notices, clear labels) still apply from 2 August 2026.

Concrete actions to take this week

• Map your Article 50 exposure — List your “chatbot/assistant”, “AI‑generated or manipulated content”, and “emotion/biometric recognition” use cases. For each, document the entry point, transparency message, a screenshot, and the link to your policy.
• Implement visible notices — Roll out a “You are interacting with AI” banner/label on every relevant interface; add the “AI‑generated/manipulated content” label to public‑interest publications; insert the specific warning for emotion/biometric recognition where applicable.
• Prepare evidence and the machine‑readable track — Build a two‑step compliance plan (August = notices/labels + evidence; December = watermarks/technical markers for pre‑existing content), with a technical backlog, release notes, and exportable log samples. Our teams can lead this AI governance and compliance programme.
• Sign the Code of Practice — Launch legal validation and management approval; prepare your comms kit to appear on the public list in July 2026.
• Train and align — Update Comms/Legal/Product playbooks to default‑integrate the labels and icons provided by the Commission. For privacy impacts and data processing duties, align with your GDPR obligations.

Sources

• Commission publishes the Code of Practice (10 June 2026)
• How to sign the Code of Practice (10 June 2026)
• Council — “Digital Omnibus” agreement (7 May 2026)

For structured support and audit‑ready deliverables, contact our team.

Article generated by Luxgap regulatory watch. For tailored guidance on this topic, contact us.