Our Take
The Code is optional; the law is not. Companies have eight weeks to sort compliance details the Commission has not yet finished defining.
Why it matters
Any vendor or deployer serving EU users faces hard legal deadlines for three labeling categories (deepfakes, AI-generated public-interest text, and chatbot interactions) whether they sign the Commission's playbook or not. The gap between the August 2 deadline and missing clarifying guidelines creates real execution risk.
Do this week
Legal: audit your product's content flow against Article 50 requirements (deepfakes, AI text without editorial review, interactive AI disclosure) before July 1 so you have one month to implement and test your labeling stack.
The EU released its AI labeling playbook on June 10
The European Commission published a final Code of Practice setting out how companies should mark and label AI-generated or AI-manipulated content. The Code is voluntary. The rules it describes become law across the EU on August 2, 2026, under Article 50 of the AI Act, whether or not a company signs on.
Signing the Code gives a business a recognized compliance pathway and official recognition by the Commission. But the underlying obligations are mandatory for all providers and deployers serving European users.
Three categories require labeling from August 2 onward. Deepfakes must carry a visible label. AI-generated or AI-manipulated text published on matters of public interest must be flagged if it appeared without human review or editorial control. Anyone interacting with an interactive AI system, such as a customer-service bot, must be told they are communicating with a machine.
The Code splits responsibility between model builders and deployers. Model providers are asked to mark output in machine-readable format so downstream systems can detect it. Deployers handle the visible labeling that users see, using a common EU icon meant to give users consistent visual cues and reduce the burden of custom labeling per company.
Henna Virkkunen, the Commission's executive vice-president for tech sovereignty, framed the Code as offering practical routes to compliance: "Europeans have a right to know whether what they see, hear or read has been made or altered by AI, especially when such content can shape public debate."
The timeline is tight and guidance is incomplete
Companies have less than two months to understand which of their systems trigger the labeling rules, decide whether to sign the Code, and build or configure their labeling stack. The Commission has yet to publish separate guidelines clarifying the law and covering details the Code leaves undefined.
The Code was drafted by six independent experts with input from over 180 stakeholders, but it is the first instrument addressing AI content labeling under the Act. Subsequent Commission guidance will be the authoritative legal reference for many edge cases. Until that guidance drops, teams must work from Article 50 itself and the Code's principles.
Signing the Code signals compliance intent and may provide some legal defensibility, but does not exempt companies from the August 2 deadline or future enforcement based on the final guidelines.
Map your compliance surface now
Identify which products and features fall into the three labeled categories: deepfake generation or detection, public-interest text without editorial control, and interactive AI systems. For each, document your current disclosure or labeling mechanism and the gaps against the Code's technical standards and icon requirements.
If you build generative models, prepare machine-readable metadata tagging (the Code leans on open technical standards). If you deploy models, design the user-facing labeling and test it for coverage and clarity before July. Many teams will need to wire labeling into their content moderation and review workflows, so the timing overlap with product freeze cycles matters.
Do not wait for the Commission's full clarifying guidelines. The law applies August 2 regardless. Use the Code as your working reference and prepare for refinement once official guidance arrives.