The December 2, 2026 grace period: what it covers (and what it doesn't)
Only one thing: machine-readable marking of AI-generated content for generative AI systems already on the market before 2 August 2026. Chatbot disclosure, deepfake labels and deployer duties have NO grace period — they apply from 2 August 2026.
One grace period, precisely scoped
Article 111's transitional provisions give providers of generative AI systems placed on the market before 2 August 2026 until 2 December 2026 to implement the technical, machine-readable marking of Article 50(2).
What people wrongly assume it covers
- Chatbot disclosure → no grace period. Live from 2 August 2026.
- Deepfake labeling → no grace period.
- Deployer duties → no grace period.
The grace period is a technical-implementation window for AI providers' marking tech — not a business delay for websites. If your chatbot is live in August, your disclosure must be too. Fix it before August →
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