Article 50 is enforced nationally: each Member State designates one or more market surveillance authorities (MSAs) for the AI Act, with the deadline for doing so back on August 2, 2025. The honest status as of mid-2026: only around nine Member States have fully designated their authorities, roughly a dozen more have done so partially, and several haven't completed the step at all. Germany is furthest along among the large markets, with a national implementation act approved by cabinet in February 2026 and the Bundesnetzagentur as central authority.
Read that reality carefully, because both wrong conclusions are tempting. Wrong conclusion one: "no authority yet, so no obligations." The duties apply from August 2, 2026 by EU regulation, directly, in every Member State. Enforcement capacity affects how quickly a gap gets noticed, not whether you have it. A gap that exists in 2026 is still there, documented by your own website's history, when the authority staffs up in 2027.
Wrong conclusion two: "fines are about to rain down." Realistic early enforcement is complaint-driven and focused on easily verifiable failures (is there an AI notice at first interaction, is realistic AI media labelled, can you show evidence), with corrective orders as the likely first step, well before headline fines. For SMEs the fine ceiling is the lower of €15M or 3% of turnover (Article 99(6)), and fines are discretionary against the Article 99(7) factors.
Also in the mix: private consequences don't wait for regulators. Unfair-commercial-practices claims, customer and competitor complaints, and platform policies all reach undisclosed AI regardless of MSA staffing.
What we won't do on this page is fake a per-country table where reality is in flux; designations were actively moving through mid-2026. If your compliance position depends on the specific authority in your Member State, check your government's current announcement or ask counsel. For everyone else, the operative fact is simpler: the duties are EU-wide, cheap to meet, and dated evidence beats guessing about enforcement schedules.
Not sure how this applies to your specific setup? The free 2-minute check tells you which of the four Article 50 duty areas likely apply to your company. No email required.
Take the free check Generate disclosure text