“2 December 2026” keeps turning up in articles about the AI Act, usually next to the word “deadline”. If you run a website, you’ve probably wondered whether it’s yours.
Mostly, it isn’t. It’s a date for the companies that make AI tools. The parts of Article 50 that land on website owners have applied since August. Still, it’s a handy reminder to check that your side is in order, so there’s a checklist at the end.
A tool, not legal advice. This guide explains public documents in plain language. If the dates matter for your business, ask a lawyer.
Where the date comes from
The transparency rules in Article 50 started to apply on 2 August 2026.
Earlier in 2026 the EU agreed a package of changes to the AI Act, known as the Digital Omnibus on AI. It was published in the Official Journal as Regulation (EU) 2026/1744 on 24 July and entered into force three days later. Among much else, it gave one group a short extension.
Providers of AI systems that generate synthetic audio, images, video or text, and that were already on the market before 2 August 2026, have until 2 December 2026 to comply with Article 50(2).
Article 50(2) is the machine-readable part: watermarks, signed metadata and similar markers that software can detect. Systems released on or after 2 August get no extension.
What it doesn’t delay
Only that one duty was pushed back, and only for those providers. Everything else in Article 50 has applied since 2 August 2026, with no grace period:
- 50(1), the rule that chatbots must tell people they’re AI;
- 50(3), disclosure of emotion recognition and biometric categorization;
- 50(4), visible labels for deepfakes and for AI-written public-interest text.
So if your site has an AI chatbot or shows realistic AI images, your date has already passed. That’s less dramatic than it sounds. Fixing it usually takes an hour or two.
Are you a “provider”?
Probably not. The extension is for the makers of image generators, writing assistants, voice tools and the like. If you only use those tools on your site, you’re a deployer, and 50(2) isn’t your duty.
You might be a provider if you built your own AI system, such as a custom chatbot or image tool, and offer it under your own name. The EU AI Act for agencies with client sites explains how the roles play out.
Why the date still matters to you a little
After 2 December, more of the files that come out of AI tools should carry machine-readable markers. That changes two things for you.
First, it’s easier to know what’s AI. If someone on your team uploads an AI image and forgets to mention it, the file itself may give it away.
Second, it’s easier for anyone else to notice a mismatch. A file that says “AI-generated” inside, shown on a page that says nothing about AI, isn’t a great look.
Under the Code of Practice, watermark detection should work across different tools by 2 February 2027, so this will only get more reliable.
The checklist
Go through it once before 2 December, then again every few months. It’s grouped by duty.
The chatbot (applies now)
- Open your site in a private window and start a chat. Can you tell it’s AI before you type anything?
- Does the first reply say it’s an AI assistant?
- Is the wording plain? “This system uses LLMs” doesn’t count.
- If the bot speaks for your business, does it say whose assistant it is?
More in Chatbots on your website and the EU AI Act.
Images, video and audio (applies now)
- List the AI images and videos on your site that show real-looking people, places or events.
- Check that each one has a visible caption on or right next to it.
- If you use AI voices in audio or video, add a spoken or visible note.
More in Deepfake or not: where the line is.
Text (applies now)
- Do you publish AI-written text on news, health, finance, politics or other public topics?
- If you do, does a competent person review it and take editorial responsibility?
- If nobody reviews it, is there a visible notice?
More in Do you need to label AI-written blog posts?
Your own AI tools (2 December, for older systems)
- Did you build your own AI tool that generates content and offer it under your name? If not, skip this part.
- If you did, check that its output carries machine-readable markers.
Housekeeping
- Is there a public “How we use AI” page? There’s a template in How to write a “How we use AI” page.
- Do you keep a record of what you labeled and why?
- Does your team know who decides what gets labeled?
Content from before August
According to the Commission’s guidelines, content generated before 2 August 2026 doesn’t need to be labeled after the fact. New content is a different story, and so is old content you’ve since reworked with AI.
Fines, briefly
Breaking Article 50 can cost up to €15 million or 3% of worldwide annual turnover, whichever is higher (Article 99), with proportionate treatment for smaller businesses. The Omnibus also gave the EU’s AI Office new enforcement powers. None of this is a reason to panic. It’s a reason to spend an hour on the checklist.
How AuthorLabel helps
The first-run check asks six short questions, scans your site for chat widgets and AI plugins, and shows which duties look like yours. Article 50(2) normally comes out as “Not yours”, because it belongs to the AI provider.
When you upload files, the plugin reads C2PA, IPTC and EXIF/XMP markers and suggests a label. As more AI tools add those markers after 2 December, that gets more useful.
The readiness panel on your dashboard lists what’s still open, such as “Turn on visible labels” or “Publish a How we use AI page”. The score shows how far your setup has come. It isn’t a compliance rating.
The activity log records every label change: when, who, what and why.
Want a quick look first, without installing anything? Try the free online check.
In short
2 December 2026 is a date for AI providers, and only for machine-readable marking. Chatbot notices and visible labels for deepfakes and public-interest text have applied since 2 August 2026. Use the date as a nudge and run through the checklist.
Sources
- Regulation (EU) 2024/1689 (AI Act), Article 50 and Article 99.
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), OJ L, 24 July 2026.
- White & Case, “EU AI Omnibus enters into force, amending the AI Act” (2026). whitecase.com
- Cloud Security Alliance, “EU AI Act Article 50 watermarking deadline” (September 2026). labs.cloudsecurityalliance.org
- European Commission, Guidelines on the transparency obligations under Article 50 of the AI Act (July 2026). Not legally binding.
Last reviewed: November 2026. AuthorLabel is a tool, not legal advice.