Same NPC, Different Rules: How A Player’s Age Changes Their Responsibilities Under The AI Act

On 2 August 2026, Article 50 of the AI Act came into force across the European Union. This marks the next stage in the implementation of this regulation, which is coming into force gradually, section by section: prohibited practices have been in force since February 2025, obligations for general-purpose models since August 2025, whilst the requirements for high-risk systems – following a recent postponement of the deadlines – will, for the most part, only come into force in December 2027 (for autonomous systems under Annex III), and for systems embedded in regulated products, in August 2028 (Annex I). 

The media have reported on Article 50 mainly in the context of deepfakes and customer service chatbots, reducing it to yet another labelling requirement. But could this provision also cover generative NPCs in video games – that is, virtual characters that engage in real-time conversations with the player? The answer is: yes.