Transparency Obligations For AI‑generated Content Under The EU AI Act: From Principle To Practice

Under the EU AI Act (the Act), transparency obligations around AI‑generated content are no longer a matter of high‑level principle, but ofengineering, governance and evidentiary readiness. While the core idea - that users should know when they are interacting with AI‑generated or AI‑manipulated content - may appear, at first glance, deceptively simple, implementing these obligations in practice raises complex technical, organisational and legal questions for both AI providers and deployers.

The second draft of the Code of Practice on Transparency of AI‑Generated Content, (the Code) published on 3 March 2026 and open for stakeholder feedback until 30 March 2026, represents a decisive attempt to bridge the gap between legal obligation and technical reality. Developed under the supervision of the European Commission through a broad multi‑stakeholder process, the Code aims to operationalise Articles 50(2) to (5) of the Act by providing practical and technical guidance for real‑world