2026-12-02 · EU · 112 days from today

Providers of generative or content-altering AI systems placed on the EU market before August 2, 2026 must apply machine-readable marking as of December 2, 2026. This is the grace period end date for existing products.

What it requires

Article 50 of the EU AI Act requires machine-readable marking for certain AI systems. If your system was already in the market by August 2, 2026, you have until December 2, 2026 to comply with the marking obligations. This applies to generative AI systems and systems that can alter content. The marking must be machine-readable, meaning it is formatted for automated processing, not just human review. You should review the Commission's transparency guidelines for the required format and technical implementation.

Who it binds

Providers—organizations that place or keep generative or content-altering AI systems on the EU market. This includes vendors, developers, and importers. Compliance teams, product managers, and legal leads within provider organizations carry the implementation responsibility. Distributors and resellers may also need to ensure systems in their supply chain are properly marked.

How to check whether you comply

  • Confirm whether your AI system falls under 'generative' or 'content-altering' categories under the EU AI Act.

  • Verify that your product was on the EU market before August 2, 2026 and qualifies for the grace period.

  • Review the Commission's transparency guidelines to identify the exact machine-readable marking format and data fields required.

  • Audit your system's deployment and documentation to confirm the marking is present and machine-readable by December 2, 2026.

What teams get wrong

This is a grace period end date, not the original compliance window. Systems already on the market get extra time. Do not assume marking is optional for older products; the deadline is firm. Confirm the exact format required by the Commission's transparency guidelines—'machine-readable' has a specific technical definition in this context.

Source

This page is part of the AI Compliance Deadline Radar, which tracks every dated AI obligation across the EU, UK, and US. Updates go out in The AI Reg Brief, twice a month.

Not legal advice. This summarizes a public source so you can act on it; verify against the primary text before you rely on it.