EU AI Act: AI transparency rules take effect August 2
What it really says
The EU Digital Omnibus on AI (Regulation (EU) 2026/1744) was published in the Official Journal on July 24, 2026 and entered into force on July 27. It amends the EU AI Act in several key areas. The most immediate impact: transparency obligations under Article 50 take effect as planned on August 2, 2026. From that date, providers and deployers of AI systems must inform users when they are interacting with an AI system (e.g. chatbots), label AI-generated content with machine-readable markers and particularly watermark deepfakes, and notify individuals when emotion recognition or biometric categorization systems are used on them. At the same time, the Omnibus regulation extends deadlines for high-risk AI systems: standalone high-risk systems under Annex III now have until December 2, 2027 (instead of August 2026), and AI embedded in regulated products under Annex I until August 2, 2028. A new prohibition has been added: AI systems that generate or manipulate intimate imagery without freely given, specific, informed consent ('nudifier' apps) are banned from December 2, 2026, alongside AI-generated child sexual abuse material. Violations of the transparency obligations can result in fines of up to 35 million euros or 7 percent of global annual turnover.
Our assessment
Starting August 2, every AI system in the EU must identify itself as such. Violations carry fines of up to 35 million euros. The EU Omnibus regulation deliberately postponed high-risk AI deadlines by 16 months while keeping transparency obligations on schedule. The priority is clear: consumer-facing protections come first. Chatbots must disclose they are AI, deepfakes need watermarks. Separately, the regulation bans 'nudifier' apps from December 2026. Important context: the delay on high-risk requirements is not a retreat but a pragmatic adjustment. Harmonized standards and notified bodies were simply not ready yet. Transparency obligations, by contrast, require clear communication rather than complex technical certification. For those concerned about unregulated AI, this is a concrete signal: the EU is acting with enforceable deadlines and meaningful penalties.
Relevance for Germany
For German companies, the deadline is immediately relevant: anyone deploying or providing AI systems must comply with transparency obligations from August 2. This affects chatbots in customer service, AI-generated text in media and marketing, and emotion recognition systems. Germany's chambers of commerce (IHK) have already published guidance documents. However, Germany has not yet fully established its national supervisory authority under the EU AI Act, which may complicate practical enforcement in the first months. Regardless, the obligations apply from the deadline. German businesses should particularly review their labeling of AI-generated content: many companies already use AI for product descriptions, customer communications, or image generation without making this transparent. From August onward, this will be subject to fines.
Fact check
Regulation (EU) 2026/1744 is fully available in the EUR-Lex Official Journal and confirms all cited dates and deadlines. The transparency obligations under Article 50 from August 2, 2026 are consistently documented by IHK Nuremberg, Gibson Dunn, and governance-ai-act.de. The postponement of high-risk deadlines to December 2027 (Annex III) and August 2028 (Annex I) is established in the regulation itself and confirmed by all legal analyses. The fine ceiling of up to 35 million euros for transparency violations derives from Article 99 of the EU AI Act, which was not amended by the Omnibus regulation. The prohibition of 'nudifier' apps from December 2026 is incorporated as a new paragraph in Article 5.
Source
- • https://eur-lex.europa.eu/eli/reg/2026/1744/oj?locale=de
- • https://www.ihk-nuernberg.de/meldungen/details/eu-ai-act-transparenz-und-kennzeichnungspflichten-ab-2-august
- • https://www.gibsondunn.com/eu-ai-act-omnibus-agreement-postponed-high-risk-deadlines-and-other-key-changes/
- • https://governance-ai-act.de/wissen/eu-ai-act-august-2026-was-gilt/