Article 50 Took Effect on 2 August: What Your Webshop Needs to Show Now
The EU AI Act Is Now Live for Ordinary Businesses
For most European companies, the EU AI Act (Regulation 2024/1689) didn't really begin until 2 August 2026. There was no announcement and no grace year—the transparency obligations under Article 50 simply became applicable.
Running a chatbot on your webshop? Generating product copy with AI? Using AI-generated imagery in your campaigns? Then this applies to you directly, and there's a good chance nothing has been arranged for it yet.
"But Wasn't the AI Act Delayed?"
That's the misunderstanding doing the most damage right now. There was a delay—just not to the part that affects you.
The Digital Omnibus on AI (Regulation (EU) 2026/1744) was published on 24 July 2026 and entered into force on 27 July. It moved two deadlines for good:
1. Stand-alone high-risk systems (Annex III): from 2 August 2026 to 2 December 2027. 2. High-risk AI embedded in regulated products (Annex I): from 2 August 2027 to 2 August 2028.
What was not delayed: Article 50. The transparency obligations took effect on 2 August 2026, exactly as originally scheduled.
And Article 50 happens to be the part that applies to an ordinary webshop. High-risk is about recruitment software, credit scoring and biometrics—you're probably not there. Chatbots, AI copy and AI imagery—that's where you are.
In short: the headline was about a delay, but the rule that governs you went live on schedule.
What Article 50 Actually Requires
There are four situations in which you have to disclose:
1. Your customer is talking to AI—if you run a chatbot or AI assistant, it must be clear there's no human on the other end. An exception exists where it would be obvious to any reasonable visitor, but don't lean on it: the better your bot performs, the less that exception holds. 2. You publish AI-generated content—synthetic text, image, audio or video must be marked in a machine-readable way as artificially generated. 3. Deepfakes—image or audio realistically imitating an existing person, place or event must always be visibly labelled as artificial. 4. Emotion recognition and biometric categorisation—if you use tooling that infers emotions from image or voice, you must inform the people involved.
Concrete recommendation for webshop owners:
- Put the disclosure in the conversation itself, not in your FAQ or terms of service.
- Ask your vendors in writing how their output meets Article 50, and file the answer.
The Deadline Still Ahead: 2 December 2026
One element received a transition period. Machine-readable marking of synthetic content (Article 50(2)) applies from 2 December 2026 for generative systems already on the market before 2 August 2026. Anything placed on the market after 2 August must carry it from day one.
What this means for businesses:
- You have until early December to confirm with your suppliers that their output is marked.
- The duty to inform people already applies—that part received no extension.
Your Compliance Checklist
Work through this. It's an afternoon, not a consultancy project.
Check on your site today:
- Chatbot or live chat—does the very first interaction identify it as an AI assistant?
- AI imagery—generated model shots, lifestyle images and backgrounds. Does your tool ship metadata (C2PA / Content Credentials), and do you label visibly where required?
- AI review summaries—increasingly common in webshops, and it's AI output pointed straight at your customer.
- Customer service replies—if AI drafts your emails or tickets, disclosure becomes a live question.
- Product descriptions—purely informative product copy doesn't automatically fall under the labelling duty, but you want that reasoning written down.
- AI inventory—list every AI tool running in your business, including the ones your agency or platform provider uses. Without this overview you can't assess any of the rest.
- AI literacy (Article 4)—in force since 2 February 2025. Anyone working with AI needs a basic grasp of what the tool does and where its limits are.
What You're Actually Risking
This is where a lot of coverage goes wrong. The figure of €35 million or 7% of global turnover you see everywhere applies to prohibited AI practices—social scoring and manipulative systems. A webshop isn't there.
For breaching the transparency obligations under Article 50, the ceiling is €15 million or 3% of global annual turnover, with a proportionate approach foreseen for SMEs.
Realistically, a three-person webshop isn't getting fined millions on day one. But each member state has designated supervisory authorities—in the Netherlands, the Autoriteit Persoonsgegevens and the Rijksinspectie Digitale Infrastructuur—and it takes a competitor or an unhappy customer very little effort to file a complaint.
The bigger risk isn't the fine. It's your customers finding AI content on your site that you never labelled.
What You Don't Need Yet
Some reassurance, because plenty is being sold right now that isn't necessary:
- No harmonised standard has been published. Nothing currently confers a presumption of conformity. If a vendor promises you're "AI Act compliant via standard X", ask where that standard was published.
- ISO/IEC 42001 is useful but not mandatory, and it gives no presumption of conformity either.
- The Code of Practice on Transparency of AI-Generated Content has been final since June 2026, and signing is voluntary—though you can point to it as evidence that you're meeting Article 50.
How to Get Ahead of the Curve
The thread running through all of the above: you can't fix anything until you know where AI sits in your webshop. That's almost always more places than people expect—your platform's chatbot, the recommendation module, the copy generator in your PIM, your agency's image tool.
1. Map your AI usage—every tool, including third-party services. 2. Fix the disclosures—chatbot first, then imagery and customer-facing AI output. 3. Document the decisions—what you classified, and why.
Final Thought
2 December 2026 is still coming, with 2 December 2027 behind it. With a law that phases in like this, compliance isn't a one-off exercise—it's something you re-check as each tranche lands.
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Disclaimer: This article is for informational purposes only and does not constitute legal advice. Consult a legal professional for guidance tailored to your business.
Scan Your Website for AI Compliance
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Sources
- Regulation (EU) 2024/1689 (AI Act), Article 50—EUR-Lex
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), OJ L 2026/1744 of 24.7.2026
- European Commission, guidelines on transparency obligations under Article 50
- Code of Practice on Transparency of AI-Generated Content, June 2026
Tags
- `EU AI Act`
- `Article 50`
- `transparency`
- `webshop`
- `Digital Omnibus`
- `compliance`