Last updated: August 2026. This article reflects the current state of the AI Act following the general application of the Regulation from 2 August 2026 and the Digital Omnibus on AI, Regulation (EU) 2026/1744.

The AI Act Is Now Fully Applicable: What Your Organisation Needs to Know

2 August 2026 marked one of the most important dates in European AI regulation since the AI Act entered into force.

On that date, a significant part of the Regulation began to apply, including new transparency obligations that affect many organisations using AI. For weeks, there has been talk of €15 million fines and of having to label everything that has been touched by AI. Some of that is true. Some of it is noise. Distinguishing between the two is precisely what your organisation needs before making any hasty decisions.

What Actually Came Into Force on 2 August?

The main development is Article 50 of the AI Act, which establishes transparency obligations.

From 2 August 2026, these obligations apply to the AI systems and use cases covered by the provision, regardless of the size of the organisation. There are two particularly relevant areas.

First, when people interact directly with certain AI systems, they must be informed that they are interacting with AI, unless this is obvious from the circumstances and context.

Second, certain AI-generated or manipulated content must be marked or disclosed as such.

The European Commission’s guidelines, published on 20 July 2026, clarify the scope and practical application of these transparency obligations. From 2 August, the AI Act’s enforcement framework also applies.

What Has NOT Changed, Despite What You May Have Read

This is where it is worth turning down the noise.

The Digital Omnibus on AI, Regulation (EU) 2026/1744, postponed the application of certain obligations relating to high-risk AI systems. For high-risk systems under Annex III, the relevant obligations will apply from 2 December 2027. For high-risk systems embedded in regulated products under Annex I, they will apply from 2 August 2028.

In other words, the Omnibus postponed certain deadlines. It did not eliminate the requirements. Organisations should therefore use this additional time to identify and assess their AI systems rather than assume that compliance can simply be postponed. And one thing has not changed at all: Article 4, which requires organisations to ensure an appropriate level of AI literacy among staff, has applied since February 2025.

It was not postponed by the Digital Omnibus. If someone tells you that “AI training became mandatory this month”, they are already a year and a half late.

The Most Common Misunderstanding: No, You Do Not Have to Label Everything Created with ChatGPT

This is where much of the discussion has been exaggerated, and where organisations can make poor decisions out of fear. There is no blanket obligation to label every piece of text created with the help of AI.

The European Commission’s guidelines of 20 July 2026 clarify that the transparency obligations for AI-generated or manipulated content depend on the specific use case. In particular, the disclosure obligation for deployers concerns deepfakes and certain AI-generated or manipulated text published with the purpose of informing the public on matters of public interest, subject to the conditions established by Article 50. Human review and editorial responsibility are relevant to the application of this obligation.

In practical terms, an internal memo, a commercial email or a blog post drafted with the help of AI and subsequently reviewed by a person in your organisation does not automatically have to carry an AI label.

What applies much more clearly is the transparency obligation around direct interaction: if a person is interacting with an AI system, they should know that they are interacting with AI.

Confusing these two obligations can lead organisations to add unnecessary labels while overlooking the transparency requirements that actually apply to their AI systems.

The fact that the law does not require you to label everything does not mean that you can disengage from the issue. This is the difference between merely complying and doing it properly. Human review and editorial responsibility are not loopholes designed to avoid transparency. They reflect the importance of human judgement in determining what an organisation publishes under its name.

Transparency does not begin with a label. It begins much earlier: by not delegating the decision about what is true to a machine. Verify what AI produces. Check the underlying information. Apply human judgement before putting your name behind the result. That is what the law presupposes—and what no AI tool can do for you.

Organisations that understand this do not look for ways to avoid transparency. They look for ways to earn the trust of the people who interact with their systems.

What Should You Review in Your Organisation This Week?

First, conduct an honest inventory.

Which AI systems does your organisation use? Which of them interact directly with people? Which generate or manipulate content? Think chatbots, customer service assistants, website assistants, image generators for marketing campaigns and voice-based AI tools.

Then carry out two checks. First, verify that conversational AI systems provide the required transparency notice from the beginning of the interaction, rather than hiding it in a privacy policy. Second, determine which AI-generated or manipulated content produced by your organisation is subject to the applicable marking or disclosure requirements.

Second—and more important than any label—know who is accountable.

Article 50 makes it important to review your arrangements with AI providers. Using a third-party provider does not automatically transfer your compliance responsibilities. If your chatbot is provided by another company, your organisation may still be responsible for how that system is deployed and for the information provided to users. Due diligence does not mean simply buying technology from a reputable provider. It means understanding which obligations apply to each actor, defining responsibilities clearly and being able to demonstrate that you have done so.

What This Date Reveals Beyond Compliance

You can read 2 August as a race to add labels and avoid fines. But there is a more useful way to look at it.

The transparency requirements in Article 50 are not regulatory bureaucracy for its own sake. They recognise that people have a right to know when they are interacting with a machine and when they are exposed to certain AI-generated or manipulated content.

Doing this properly is not about putting up signs. It is about knowing how your organisation uses AI and being able to explain it. Organisations that understand this will not experience 2 August as a threat. They will see it as an opportunity to bring order to something they may have been postponing for too long: understanding where, how and why they use AI. And that clarity, when a customer complaint or audit eventually arrives, is worth far more than any label added at the last minute.

Frequently Asked Questions

What AI Act obligations came into force on 2 August 2026?

The main development was the application of the transparency obligations under Article 50 to the AI systems and use cases covered by that provision.

These include requirements concerning direct interaction with AI systems and the transparency of certain AI-generated or manipulated content.

The European Commission’s guidelines clarify the scope and practical application of these obligations.

Do I have to label all content I create with AI?

No. There is no blanket requirement to label every piece of content created with AI. The applicable obligation depends on the type of content, how it is used, whether it falls within the categories covered by Article 50, and whether the relevant conditions and exceptions apply. In particular, deployers must disclose deepfakes and certain AI-generated or manipulated text published to inform the public on matters of public interest, subject to the conditions established by the AI Act.

What is particularly important for organisations is to ensure that people are informed when they are directly interacting with an AI system, where Article 50 requires such disclosure.

Did the Digital Omnibus postpone the AI Act?

Only certain provisions.

Regulation (EU) 2026/1744 postponed the application of obligations for certain high-risk AI systems to 2 December 2027 for systems under Annex III and 2 August 2028 for systems under Annex I. It did not postpone the Article 50 transparency obligations, which apply from 2 August 2026, nor did it postpone the AI literacy obligation under Article 4.

How much can AESIA in Spain fine an organisation for violating the transparency obligations?

The AI Act provides different maximum fines depending on the type of infringement and the actor involved.

For infringements of Article 50 transparency obligations, the applicable maximum for undertakings is up to €15 million or 3% of worldwide annual turnover for the preceding financial year, whichever is higher, subject to the specific rules and limits established by Article 99.

For small and medium-sized enterprises, including start-ups, the applicable maximum is the lower of the relevant percentage or amount under the AI Act’s specific provisions.

In Spain, the national authorities are responsible for supervising and enforcing the AI Act within their respective competences.

Sources

• Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act). Official Journal of the European Union.

• Regulation (EU) 2026/1744, amending Regulation (EU) 2024/1689 as regards the application dates of certain obligations relating to high-risk AI systems.

• European Commission, Guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act, 20 July 2026.

• European Commission, AI Act — Regulatory framework for artificial intelligence.

• European Commission, Questions & Answers: Transparency obligations under Article 50 of the AI Act.

• European Commission, Code of Practice on Transparency of AI-Generated Content.

• European Commission, EU Icons for Labelling AI-Generated Content.

• AI Act Service Desk, Article 50: Transparency obligations for providers and deployers.