The machine-readable marking duty under Article 50 has applied since 2 August 2026. Systems already placed on the market before that date were given a grace period to 2 December 2026.
That is now the closest live deadline in the AI Act — three months out — and it is the one most likely to be missed, for a straightforward reason: marking is an engineering change, not a policy document. It requires provenance metadata to be attached at generation time and to survive the pipeline. Drafting a policy that says content will be marked takes an afternoon; making outputs actually carry a detectable signal touches the system.
Worth checking now
- Which of your systems generate audio, image, video or text that reaches people outside your organisation.
- Whether marking survives your processing chain, or is stripped by resizing, transcoding or re-encoding.
- Whether the carve-out for text under human editorial review applies to you — and whether you could evidence that review if asked.
The last of those is the one we would look at first. "A human reviewed it" is a claim, and claims that have never been tested tend to be weaker than the people making them expect.