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Check the limited December 2026 AI marking transition
Check which existing AI systems qualify for the 2 December 2026 marking transition and keep other Article 50 transparency duties on their own schedule.
A vendor’s reference to a December 2026 deadline should trigger a scope check. It is not a reason to postpone every transparency task in a marketing organization. Identify the exact system and obligation behind the statement before changing the campaign release plan.
Understand the narrow transition
The Commission identifies a transition until 2 December 2026 for Article 50(2) marking and detection duties concerning AI systems placed on the market before 2 August 2026. [1] Its FAQ distinguishes this from Article 50’s general application from 2 August. [2] The transition is about a specific provider duty and qualifying systems, not a blanket extension for all AI uses.
Ask for system-level evidence
Request the system name, provider, relevant market-placement date and the obligation for which the vendor claims the transition. A supplier’s incorporation date or the date your organization signed a subscription is not the same evidence. Ask how the supplier treats materially different products or versions and have unresolved scope questions reviewed by qualified specialists.
Keep other work on its own track
Maintain separate review items for interaction notices, relevant deployer disclosures and applicable content rules. For example, a video campaign should still receive its own disclosure assessment rather than inheriting the software provider’s deadline. Record the decision owner for each item and the source supporting any exception. This makes the transition visible without letting it become a general waiver.
Plan a verifiable provider follow-up
Before the claimed transition ends, ask for documentation and sample outputs showing the marking approach in the service you use. Include exports and downstream editing in the operational test, since a campaign passes through several tools. Record what has been verified and what still depends on the provider. A clear transition register helps procurement, legal and production teams work from the same facts as the deadline approaches.
Sources and evidence
Sources checked on 4 October 2026. Proposed workflows and hypothetical examples are editorial analysis.
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