August 2, 2026 is when Article 50's transparency duties — chatbot disclosure, generative-system marking, and content labelling — become applicable. This date was not moved by the June 2026 Digital Omnibus, which postponed only the separate high-risk-system rules.
The verified sequence around it: penalty and governance provisions (Article 99) plus Market Surveillance Authority designation were already applicable from August 2, 2025 — though many Member States missed that designation deadline. The Commission's draft Article 50 Guidelines were published May 8, 2026, with consultation closing June 3; the final guidelines are still pending as of this writing. The final Code of Practice on Transparency of AI-Generated Content was published June 10, 2026 — its text is final, though signing it is voluntary. The European Parliament adopted the Digital Omnibus's provisional agreement on June 16, 2026, but Official Journal publication is still pending. July 22, 2026 is the deadline for the initial Code of Practice signatory list, though late signing is understood to remain possible.
Then, on August 2, 2026, Article 50 obligations apply. This is confirmed and not affected by the Omnibus, which moved only high-risk-system deadlines: Annex III use cases to December 2, 2027, and Annex I to August 2, 2028.
One nuance worth knowing: December 2, 2026 marks the end of a grace period, but only for the machine-readable marking element of the generative-system duty (Article 50(2)), and only for systems already on the market before August 2, 2026. That grace period doesn't touch the chatbot disclosure duty or the published-content labelling duties — both of those apply from August 2, 2026 regardless. It's also contingent on the Digital Omnibus's Official Journal publication, which was still pending at the time of writing — worth re-verifying before you rely on it.
If you're building a compliance timeline for your own company, the practical read is: treat August 2, 2026 as your one real deadline for everything except generative-system marking, and don't let news about the Digital Omnibus's other, later high-risk deadlines (December 2027, August 2028) lull you into thinking Article 50 moved too — it didn't.
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