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ARTICLE · 23 JUNE 2026

Deepfakes, Chatbots, AI-Generated Text: European Commission Details Transparency Obligations Under The AI Act

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The European Commission has published draft guidelines interpreting the AI Act's transparency obligations, establishing when and how organizations must disclose AI-generated content, deepfakes, and automated interactions. These guidelines clarify that deepfake labeling applies regardless of intent to deceive, that AI systems must identify themselves at the point of interaction, and that the editorial review exception for AI-generated text requires substantive human oversight with clear accountability.

European UnionTechnology
Philip Radlanski
Philip Radlanski
Carsten Kociok
Carsten Kociok

Read in German.

On 8 May 2026, the European Commission published draft guidelines on the implementation of the transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act). The draft guidelines describe how the AI Act’s four transparency obligations are intended to apply to (i) interactive AI systems; (ii) providers of AI systems that generate or manipulate synthetic content; (iii) deployers of emotion recognition and biometric categorization systems; and (iv) deployers of deepfakes and AI-generated text on matters of public interest. While non-binding, European Commission guidelines carry considerable practical importance in the application of EU law.

Key Takeaways

  • Deepfake rules apply even without intent to deceive. Content that looks or sounds like a real person must be labeled – even if no deception was intended and even if no real individual is depicted. (Art. 50(4) AI Act)

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