EU AI Act

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Seyfarth Synopsis: On Thursday 30 July, the European Commission issued a press release advising that EU AI Act enforcement begins this SUNDAY, 2 August 2026, when the Act’s transparency rules start to apply. Chatbots and other interactive AI systems need to be ready to identify themselves. Deepfakes and AI generated content needs to be labelled. There are limited exceptions.

The EU AI Act’s Article 50 transparency obligations apply broadly, with the stated goal of reducing the risks of impersonation, deception, misinformation and manipulation at scale and fraud and mitigating the potential detrimental effects of AI generated or manipulated content and interactions. Organizations (and in some cases, individuals) using chatbots, generative AI, deepfake functionality, emotion recognition, biometric categorization, or AI-generated public-interest content should assess whether disclosures, labeling, or content-marking requirements apply without delay. The principal exception is a short implementation period for the Article 50(2) machine-readable marking requirement. Under the EU’s Digital Omnibus reforms, providers of certain generative AI systems already placed on the EU market before August 2, 2026 have until December 2, 2026 to implement those marking measures, while the remaining Article 50 transparency obligations continue to take effect on August 2, 2026. Noncompliance carries fines of up to €15 million or 3% of total worldwide turnover.

Continue Reading European Commission Press Release: EU AI Act Transparency Enforcement Starts This Sunday! Do You Know Who Your Chatbots Are? We Break Down the Commission’s Guidelines on Transparency Below

The handbrake has been pulled on aspects of the EU’s AI Act (Act), with key workplace rules, particularly those on high-risk systems, pushed back from August 2, 2026, to December 2, 2027. 

The delay may feel welcome for multinational employers keeping up with the spread of AI adoption across their organization, but it is an opportunity to get the groundwork done. 

The European Commission in late May published draft guidelines on the classification of high-risk AI systems (Guidelines, https://bit.ly/4vDtgOV) for the Act. This is the clearest indication yet of how EU workplace AI tools will be treated, using many real examples.

 To function efficiently across borders, business must incorporate these rules into their global compliance framework for legal, HR, talent acquisition, procurement, IT, data, compliance and operations. 

The extra months are useful runway, because HR, recruitment, performance management and workforce allocation tools will require the full gamut of “high-risk” systems compliance. Global employers need time to work this into a matrix of other global rules — including in multiple US jurisdictions (e.g., California, Colorado, Connecticut, New York), Canada, Korea’s Basic AI Act, the updated UK GDPR and emerging rules elsewhere. 

Below is a pragmatic look at what use cases trigger the Act, and what global employers need to do from governance, procurement, data protection and employee relations perspectives. 

Continue Reading Workplace AI — How Employers Should Prepare for the New EU AI Act Deadline