EU AI Act: Early Adopters Embrace New Transparency Code
A new voluntary Code of Practice offers a clear path for providers and deployers to comply with the EU AI Act's Article 50 transparency obligations, and non-signatories may face greater regulatory scrutiny.
In the first month since its publication, approximately 190 organizations have signed the EU's new voluntary Code of Practice on Transparency of AI-generated Content. The Code provides a framework for companies to meet their transparency obligations under Article 50 of the EU AI Act, which largely took effect in August 2026. Early signatories include major technology providers like Google, OpenAI, and Anthropic, who have publicly detailed their implementation of technical measures like digital watermarking to align with the Code.
For sophisticated counsel and their clients, the Code offers a clear and defensible safe harbor for demonstrating compliance with key transparency provisions. Although voluntary, the European Commission has signaled that competent authorities will likely apply greater scrutiny and make more detailed information requests to non-signatories. The Code thus establishes a practical benchmark for regulatory expectations. Companies providing or deploying AI systems in the EU must now assess the Code's specific commitments against their own compliance strategies and decide whether to formally adopt this framework. Signatories will be invited to join task forces to help shape the code's ongoing evolution.