Commission Opinion of 8 July 2026 on the assessment of the Code of Practice on Transparency of AI-generated Content — C(2026) 4839 final

(40) In light of the above, the Commission considers that Section 2 of the Code adequately facilitates the effective implementation of the transparency obligations laid down Articles 50(4) and (5) AI Act and that deployers of AI systems may rely on the Commitments and Measures set out therein to demonstrate compliance with those obligations.

3.4. Additional consideration for the facilitation of an effective implementation: clear objectives, guiding recitals, commitments and measures

(41) Each section of the Code outlines clear objectives and includes guiding principles that provide clarity to providers, deployers, and competent market surveillance authorities in the implementation of the commitments and the measures envisaged in the Code.

(42) In addition, the Commitments entail purpose-clauses phrased as “in order to” or “for the purpose of” that set out the Commitments’ specific objectives (see, for example, Commitment 1 of each Section).

(43) Moreover, measures distinguish between varying levels of legal commitment – using terms such as “will,” “encourages,” and “may” – to ensure clarity and eliminate ambiguity for future Signatories. These terms have been explicitly defined.

(44) Section 1 enhances transparency by incorporating a glossary that defines key technical terms used in the Code.

(45) Section 2 further supports practical understanding through an annex detailing the publicly available EU icon.

(46) The Code’s Commitments and Measures outlined above are clearly directed to achieve their specific objectives described in their purpose-clauses and, in doing so, facilitating an effective implementation of the obligations under Articles 50(2) and Article 50(4) AI Act and the horizontal disclosure requirements in Article 50(5) AI Act.

3.5. Practical solutions accounting for the needs of interested parties

(47) To facilitate the effective implementation of the transparency obligations, the development of the Code must account for the needs and interests of all stakeholders. This ensures that practical and workable solutions are identified, while enabling providers and deployers to sign up to the Code with ease.

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(48) Throughout the development process, stakeholder feedback has been actively sought and incorporated in an inclusive and transparent manner, ensuring that the final Code duly supports the practical implementation of the commitments undertaken by Signatories.

3.6. Code of Practice and Guidelines on Article 50 AI Act

(49) Furthermore, the Code does not alter the Commission’s responsibility to provide guidance on the application of Article 50 AI Act. To provide clarity on the scope and legal concepts of the transparency obligations under Article 50 AI Act, the Commission will issue guidelines, as required under Article 96(1)(d) AI Act. Those guidelines will be relevant to understand concepts outlined in the Code and, in conjunction with the Code, will contribute to the effective implementation of Articles 50(2),(4) and (5) AI Act.

4. REVIEW AND ADAPTATION OF THE CODE

(50) In accordance with Article 56(6) AI Act, the AI Office and the Board will regularly monitor and evaluate the achievement of the objectives of the Code and its contribution to the effective implementation of Articles 50(2),(4) and (5) AI Act, particularly in light of the rapidly evolving landscape of technologies, as well as risks of misinformation and manipulation at scale, fraud, impersonation and consumer deception, which both transparency obligations aim to address.

(51) The AI Office will consider facilitating formal updates to the Code at least every two years, for instance based on the emergence of standards or relevant technological developments. To monitor the achievement of the objectives of the Code, the AI Office will remain in exchange with Signatories to understand where implementation support is necessary, and it may cooperate with national competent authorities, downstream providers, rightsholders, and other actors. It will also support the establishment and functioning of the task-forces envisaged under both sections of the Code, which will play a key role to advance the effective implementation of the Code and keep it practical, aligned with the state of the art, and future-proof.

5. CONCLUSION