AI Act: labelling of AI‑generated content — deadline on 2 December

Key takeaways — The Council of the EU approved an “AI Omnibus” that grants a grace period for labelling AI‑generated content for systems already marketed by 2 August 2026: the Article 50(2) requirement applies by 2 December 2026 at the latest. Other transparency duties (chatbots, deepfakes, manipulated content) have applied since 2 August 2026.

The facts

On 29 June 2026, the Council gave its final green light to adjustments streamlining certain AI Act milestones. The Commission confirmed entry into force on 27 July 2026 and issued operational guidelines on 20 July 2026 to help providers and deployers comply.

Legal framework

• AI Act Article 50 — transparency obligations: user information during chatbot interactions (50(1)), “clear, intelligible and effective” labelling of AI‑generated content by providers (50(2)), and reinforced requirements for detecting manipulated content (50(3)–(5)).
• AI Omnibus — targeted deferral of provider‑side content labelling to 2 December 2026 for systems already on the market by 2 August 2026; no change for deployers.

This aligns with the proactive transparency approach promoted under the GDPR and by data protection authorities.

Impact in Luxembourg

• Who is affected — Providers of generative systems (text, image, audio/video, SaaS) accessible in the EU, and Luxembourg‑based deployers (companies, media, public bodies, financial institutions) publishing generated or manipulated content.
• Timelines and risk — Deployers: obligations effective since 2 August 2026 (clear signalling, contextual notices). Providers: grace period until 2 December 2026 only for systems already marketed by 2 August; new systems must comply upon market launch.

What to do now

• Map roles and use cases — Distinguish your “provider” vs “deployer” roles, link each use case to the relevant paragraphs of Article 50, and document the EU scope.
• Decide and test your labelling — Combine mechanisms (visible watermark, C2PA/metadata tagging, audio cue) and measure persistence after cropping, recompression, transcription or copy/paste.
• Update journeys and evidence — Add “AI‑generated content” notices to web templates, newsletters, players and social feeds; publish an “AI Transparency” policy; assemble a compliance file (register, applicability decisions, labelling design, test protocols and results, exemption procedure and remediation plan before 2 December 2026).

Go further

To structure governance and controls, leverage our AI compliance and AI Act governance service and our overview of the AI Act legal framework. If you deploy generative systems in Luxembourg and need hands‑on support, see our AI compliance Luxembourg focus or reach out via our contact form.

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