When do the EU AI Act Article 50 transparency obligations apply?

Most Article 50 transparency obligations apply from 2 August 2026, including AI interaction disclosure (50(1)), biometric and emotion-recognition notice (50(3)), and deepfake and public-interest text labelling (50(4)). Under the May 2026 Omnibus agreement, the machine-readable marking obligation in Article 50(2) is deferred to 2 December 2026, but only for generative AI systems placed on the EU market before 2 August 2026. Systems placed on the market from 2 August 2026 must comply with all four categories from that date. Non-compliance can attract fines of up to €15 million or 3% of worldwide annual turnover.

Do standard commercial insurance policies still cover AI-related liability in 2026?

Increasingly, no. Beginning in January 2026, state regulators approved the large majority of carrier requests to add AI exclusions to commercial general liability policies, including ISO endorsements CG 40 47, CG 40 48 and CG 35 08. Some carriers have adopted absolute AI exclusions in D&O, employment practices and professional liability lines, in certain cases disclaiming coverage for claims arising from inadequate AI governance, policies or training. Exclusion endorsements generally attach at policy renewal. A separate market of affirmative, standalone AI liability coverage has emerged from specialized carriers.

What is the Code of Practice on Transparency of AI-Generated Content?

The European Commission's Code of Practice on Transparency of AI-Generated Content was finalized on 10 June 2026. It is a voluntary instrument supporting compliance with Article 50 of the EU AI Act; providers may formally sign it, and the Commission has published voluntary transparency icons for AI-content disclosure. Signing offers a streamlined pathway for demonstrating compliance with the transparency obligations.

Independent · Indexed · Machine-checked

The independent register of AI governance.

Two records now govern enterprise AI: what regulators require you to disclose, and what insurers will still cover. Certian indexes, compares, and machine-checks the public facts on both — the certifications, the obligations, and the exclusions. We issue no standards and audit no systems. We keep the record.

cer·tian /ˈsɜːr·ʃən/ noun

1. One who keeps the record — date-stamped, sourced — and leaves the conclusions to others. 2. (the) Certian: the independent register of AI governance, at certian.com.

From the Latin certus — settled, fixed — with -ian, the ending English reserves for its record-keepers: librarian, custodian, historian.

The librarian doesn’t write the books. The historian doesn’t make the history. The certian doesn’t make the call.

Certain is a claim. Certian is a record.

One letter short of certain, by design.

Which deadline applies to your systems? — Use the screener → Certian Signatory Count: ~190 · S1: 82 · S2: 152 · as published, retrieved 17 Aug Last entry: 26 Aug · One state now asks insurers whether AI wrote the filing — two have answered, both no

The regulatory record — Article 50, as it stands

EU AI Act · Reg. (EU) 2024/1689 · updated 2 Aug 2026

AI interaction disclosure — Art. 50(1) Chatbots, voice assistants, and other systems interacting with people must disclose they are AI, unless contextually obvious.

In application since2 AUG 2026

In force

Machine-readable marking of synthetic content — Art. 50(2) Generative outputs must be marked and detectable. Deferred to 2 Dec 2026 only for systems already on the EU market before 2 Aug 2026; new systems comply from 2 Aug.

Legacy systems2 DEC 2026

— days

Biometric & emotion-recognition notice — Art. 50(3) Deployers must inform individuals when these systems process their biometric data.

In application since2 AUG 2026

In force

Deepfake & public-interest text labelling — Art. 50(4) AI-generated or manipulated content that appears authentic must be clearly disclosed, with carve-outs including human editorial responsibility.

In application since2 AUG 2026

In force

Non-compliance: fines up to €15,000,000 or 3% of worldwide annual turnover, whichever is higher. Enforcement powers active from 2 August 2026 — national market surveillance authorities, the AI Office, and the EDPS.

Primary sources: Regulation (EU) 2024/1689, Article 50 · Commission Guidelines on Article 50 transparency obligations (final, adopted 20 July 2026) · Code of Practice on Transparency of AI-Generated Content (final, 10 June 2026) · AI Omnibus — Regulation (EU) 2026/1744 (in force 27 July 2026) · Commission announcement on entry into application (2 Aug 2026) · Commission press release — enforcement begins (IP/26/1714). Summary of public regulatory information; not legal advice.

The insurance record — AI exclusions, as filed

US commercial lines · updated 26 Aug 2026 · the record

Generative-AI exclusion endorsements — ISO CG 40 47 / CG 40 48 / CG 35 08 New endorsement forms permit carriers to remove generative-AI liability from standard commercial general liability policies.

Effective from1 JAN 2026

In market

Absolute AI exclusions — D&O, EPL & professional lines Carrier-specific forms disclaiming coverage for claims arising from AI use — in some filings, from inadequate AI governance, policies, or staff training itself.

Attach atRENEWAL

Spreading

Affirmative standalone AI liability coverage A specialist market of standalone AI coverage has emerged from carriers and MGAs, priced against documented AI governance.

Market statusEMERGING

Indexed

The gap between what companies deploy and what their policies now cover is among the least-documented risks on a 2026 balance sheet. Certian's insurability review and exclusion-filing index put the public record in one place. Exclusion endorsements generally attach at policy renewal — the review window is before yours.

Which deadline applies to your systems — and what does your policy still cover?

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The Certian register

Instruments · status as of 18 Aug 2026

What the register currently keeps: the instruments below, the jurisdiction record, the signatory record and Count, the guides, and the date-stamped changelog of it all. A vendor listing layer is planned, not yet open. The record states what it keeps — nothing more.

Live · 16 Jul 2026

Article 50 Applicability Screener

An interactive decision tree mapping each of your AI systems — as provider or deployer — to the August and December obligations, with the regulation text one click away at every branch.

Live · 18 Aug 2026

AI Coverage Litigation Register

Decided US cases turning on an AI exclusion endorsement or an affirmative AI liability policy. Opened while the record was empty — no decided case is recorded, and the date on which that was last true is part of the record.

In preparation

AI Insurability Review

A structured, un-scored review of where your AI use and your commercial policies no longer overlap, producing a factual record you can bring to your broker at renewal.

Live · 15 Jul 2026

Code of Practice Signatory Register

A public, date-stamped record of which AI providers have signed the Commission's June 10 Code of Practice on Transparency — free, date-stamped, and citable.

Live · 17 Aug 2026

AI Certification Comparison

Four pathways — ISO/IEC 42001, IEEE CertifAIEd, Responsible AI Institute, Nemko — set against the same attributes: what is assessed, who assesses it, whether a public register of holders exists, and what each does and does not confer under the EU AI Act.

Live · 12 Aug 2026

AI Insurance Filings Index

A record of AI insurance filings on both sides of the market — exclusion endorsements and affirmative AI liability products — organisation, form, line, status, and date, each entry sourced.

Guides — the questions to ask Brokers · AI exclusions Counsel · disclosure laws AI vendors · before you sign IT providers · AI controls Consultants · vetting

For IT providers & commercial brokers

Certian's insurability review is being prepared as a white-label instrument for managed service providers and brokerages serving mid-market clients — a client-ready deliverable for the renewal conversations already on your calendar. Early partner conversations are open now.