EU AI Act's draft Code of Practice on AI-generated content marking and labelling sets August 2026 compliance deadline, with Kennedys warning organisations to act now

The EU AI Act's draft Code of Practice on the marking and labelling of AI-generated content has been published, setting out the practical compliance benchmark for Article 50 of the Act — the provision that requires providers and deployers of AI systems to disclose when content has been artificially generated or manipulated. The transparency obligations under Article 50 become applicable on 2 August 2026, giving organisations less than five months to implement compliant systems. Analysis published by Kennedys Law sets out the key compliance architecture. The Code addresses Article 50(2) and 50(4) obligations together with Article 50(5), and is expected to become the de facto standard against which regulators assess compliance — meaning organisations that depart from the Code without justification risk adverse regulatory findings even if their technical systems otherwise comply with the Act's text. Practical compliance requires action across five domains: scope assessment (determining which AI systems and outputs trigger the obligation), governance (internal accountability structures), documentation (audit-trail records), technical controls (watermarking or metadata embedding), and contracts (updating vendor agreements and deployment terms to flow through disclosure obligations). Kennedys advises that delaying remediation until the rules apply on 2 August 2026 will cause greater operational disruption and that organisations should begin compliance preparation immediately. The Code is one of several delegated instruments under the AI Act being developed on a compressed timetable, alongside codes covering general-purpose AI models and prohibited AI system classifications, collectively building out the Act's practical enforcement architecture ahead of its phased application schedule.