What are the fines for violating Article 50 of the EU AI Act?

Non-compliance with Article 50's transparency obligations falls under Article 99(4) of the AI Act: administrative fines of up to 15 million euros or, if the offender is an undertaking, up to 3% of its total worldwide annual turnover for the preceding financial year, whichever is higher. For SMEs, including start-ups, the lower of the two applies. This is not the top tier: Article 5 prohibited-practice violations carry up to 35 million euros or 7%.

EU AI Act 46-Day Sprint — Cybersecurity News

Q: What happens on 2 December 2026 for Article 50?

2 December 2026 is the end of the narrow grace period for Article 50(2) machine-readable marking: providers of generative AI systems already on the market before 2 August 2026 must have their marking in place by that date. Newer systems and all other Article 50 duties have applied since 2 August 2026 with no grace period.

Q: Am I a provider or a deployer under the EU AI Act?

Roughly: the provider is the party that develops an AI system and places it on the market or puts it into service under its own name (Art. 3(3)); the deployer is the party that uses an AI system under its authority (Art. 3(4)). A creator who calls a generation API is generally the deployer of that system, not the provider. The role decides which Article 50 limb applies to you.

Q: Is this checklist legal advice?

No. This is automated guidance, not legal advice. Every checklist item cites the relevant limb of Article 50 of Regulation (EU) 2024/1689, and you should confirm your obligations with qualified counsel before relying on them.

This cybersecurity news compliance checklist is a 46-day sprint plan for the EU AI Act Article 50(2) machine-readable marking deadline of December 2, 2026. Transparency duties are already live — this cybersecurity news guide covers inventory, marking, and audit.

What is the cybersecurity news EU AI Act 46-day sprint?

The 46-day sprint is a compliance checklist for the EU AI Act Article 50(2) machine-readable marking deadline of December 2, 2026, for systems already on the market. It walks through six steps — inventory, live duties, marking, documentation, training, and a pre-deadline audit — so nothing is left to the final week.

Article 50 transparency obligations have applied since 2 August 2026 — but providers of generative AI systems already on the market before that date get one grace period: until 2 December 2026 to put machine-readable marking on synthetic outputs (Art. 50(2)). From today, October 17, that is 46 days. This checklist works the six weeks backward from the deadline, week by week, with the exact article limb cited on every item.

What non-compliance costs. Violating Article 50 falls under Article 99(4): administrative fines of up to €15 million or 3% of total worldwide annual turnover, whichever is higher. For SMEs, including start-ups, the lower of the two applies. Note: that is not the top tier — prohibited practices under Article 5 carry up to €35M or 7%. (Source: European Commission, AI Act Service Desk on Article 99 — linked below.)

WEEK 1 — OCT 17–23

Inventory your AI touchpoints

You can't label what you haven't mapped. This week is a census.

List every AI touchpoint that can reach EU users — chatbots, voice agents, image/video/audio/text generators, emotion-recognition and biometric tools. The Act follows the market: EU reach is what counts.Art. 50 scope For each system, record your role: provider (you built it / put it into service under your name) or deployer (you use it under your authority).Art. 3(3)–3(4) roles; Art. 50 duties split by role Flag every generative system you placed on the market before 2 August 2026 — these are the ones the 2 December 2026 grace period covers. Anything newer has no grace period.Art. 50(2) transition

WEEK 2 — OCT 24–30

Close the already-live duties

Most Article 50 duties have applied since 2 August — no grace period. Close the gap this week.

Chatbots, voice agents, and avatars: make sure every one clearly informs the person they're interacting with AI — in the interface and at the first interaction. Don't rely on "it's obvious."Art. 50(1); Art. 50(5) timing Deepfakes and AI-generated public-interest text: add visible disclosure that the content was artificially generated or manipulated.Art. 50(4) — deployer duty Emotion-recognition and biometric categorisation systems: notify every exposed person of the system's operation and confirm personal data is processed per GDPR.Art. 50(3) — deployer duty

WEEK 3 — OCT 31–NOV 6

Machine-readable marking

The core of the 2 December deadline: marking synthetic outputs so they are detectable as AI-generated.

Provider duty: ensure synthetic audio, image, video, and text outputs are marked in a machine-readable format, detectable as artificially generated or manipulated.Art. 50(2) — provider duty Check your marking solution is effective, interoperable, robust, and reliable as far as technically feasible — considering content type, implementation costs, and the state of the art.Art. 50(2), technical standard Note the exception: the duty doesn't apply where the system only performs an assistive function for standard editing or doesn't substantially alter the input data.Art. 50(2) exception If you're a deployer: ask each AI provider in writing how they meet Art. 50(2) marking, and add contract language covering labelling features, metadata retention, and a ban on stripping marks.recommended practice — ask, don't assume

WEEK 4 — NOV 7–13

Documentation

Regulators audit paper trails. Build yours before the deadline, not after.

Document your marking and labelling measures per output type — what mark is applied, how it's detected, and what happens if it's removed downstream.Art. 50(2), Art. 50(4) Keep every vendor's written marking answer, your inventory, and disclosure screenshots in one dated compliance file.recommended practice — evidence file

WEEK 5 — NOV 14–20

Staff training

The duties live where your people publish. Make the rules muscle memory.

Train content and social teams: every deepfake and every AI-generated public-interest text must carry visible disclosure before publication.Art. 50(4) Train product teams: first-interaction disclosure on every conversational AI surface — and keep the proof (screenshots) with each release.Art. 50(1), Art. 50(5)

WEEK 6 + FINAL DAYS — NOV 21–DEC 2

Pre-deadline audit

12 days to verify, then the grace period ends.

Audit every legacy generative system flagged in Week 1: machine-readable marking live and verified detectable by 2 December.Art. 50(2) — 2 Dec 2026 deadline Spot-check visible labels in production: chatbot disclosures, deepfake labels, emotion-recognition notices — all clear, distinguishable, and at first interaction.Art. 50(1), 50(3), 50(4), 50(5) Confirm leadership knows the exposure: Art. 99(4) — up to €15M or 3% of global turnover for Article 50 violations — and your evidence file is complete.Art. 99(4)

Official sources:
EUR-Lex — Regulation (EU) 2024/1689, the EU AI Act (full text)
EUR-Lex — consolidated AI Act text as amended 27 July 2026 (Digital Omnibus)
European Commission AI Act Service Desk — Article 99 penalties
The 2 December 2026 grace period for Article 50(2) marking of systems on the market before 2 August 2026 is reported by multiple compliance analyses; other Article 50 duties have applied since 2 August 2026 with no grace period. The Digital Omnibus on AI (Regulation (EU) 2026/1744) delayed high-risk deadlines but not Article 50.

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Frequently asked questions

What is EU AI Act Article 50?

Article 50 of the EU AI Act (Regulation (EU) 2024/1689) sets transparency obligations: providers of direct-interaction systems must inform users they're interacting with AI (50(1)); providers of synthetic content generators must mark outputs machine-readable (50(2)); deployers of emotion-recognition/biometric systems must inform exposed persons (50(3)); deployers must disclose deepfakes and AI-generated public-interest text (50(4)). Applied since 2 August 2026.

What happens on 2 December 2026 for Article 50?

It's the end of the narrow grace period for Article 50(2) machine-readable marking: providers of generative AI systems already on the market before 2 August 2026 must have marking in place by then. Newer systems and all other Article 50 duties have applied since 2 August 2026 with no grace period.

Am I a provider or a deployer under the EU AI Act?

Roughly: the provider develops an AI system and places it on the market or puts it into service under its own name (Art. 3(3)); the deployer uses an AI system under its authority (Art. 3(4)). A creator calling a generation API is generally the deployer, not the provider. Your role decides which Article 50 limb applies.

What are the fines for violating Article 50?

Under Article 99(4): up to €15 million or 3% of total worldwide annual turnover, whichever is higher. SMEs and start-ups pay the lower of the two. That's not the top tier — Article 5 prohibited-practice violations carry up to €35M or 7%.

Is this checklist legal advice?

No — automated guidance, not legal advice. Every item cites its Article 50 limb, but confirm your obligations with qualified counsel before relying on them.

The 46-Day Sprint: your EU AI Act Art. 50 compliance checklist. — Cybersecurity News