Labeling requirement for AI content

Since the August 2, 2026 the transparency obligations of Article 50 of the AI Regulation (AI Act) apply. Not only for developers but for every company that uses AI. Anyone operating a chatbot on the website, publishing AI-generated images or texts, or using synthetic voices in customer service must make this visible to users. The European Commission has outlined what specifically needs to be labeled:

The AI Omnibus comes into force: Since July 27, 2026, the amendment to the AI Act applies: The obligations for high-risk systems will only take effect from December 2027 or August 2028, simplified documentation and proof obligations apply to SMEs.

Who does the AI Regulation affect?

The regulation encompasses every company or organization that uses AI tools. Operators of AI systems are defined in the AI Regulation as "natural or legal persons, authorities, institutions, or other bodies that use an AI system on their own responsibility." This includes all professional applications. Only private, non-professional uses are excluded.

For all operators, Article 4 applies since February 2, 2025: sufficient AI competence of employees. How much more you need depends on what you use AI for. You should take a closer look if you ...

• use AI in personnel selection, credit checks, or critical infrastructure – such applications are considered high-risk according to Annex III, even with purchased tools,

• operate in a regulated industry such as healthcare, financial services, or transport,

• work with personal data or copyrighted content,

• develop or train your own AI systems – then you are also considered a provider, with significantly more extensive obligations.

The earlier you know the legal frameworks, the safer and faster you can implement AI projects without having to make corrections later.

Implement AI Act with the Bavarian AI Innovation Accelerator

Training, workshops, and practical aids for implementing the AI Act. The Bavarian AI Innovation Accelerator is a project funded by the Bavarian State Ministry for Digital Affairs for initially two years. Within the framework of the project, SMEs, startups, and the public sector in Bavaria are supported in complying with the European AI Regulation.

Implement AI Act: 5 steps for your company

The following approach has proven effective for many companies:

• Step 1 – Check relevance:
  Clarify whether your company qualifies as an operator of an AI system within the meaning of the AI Regulation. This concerns every professional use of AI tools, regardless of company size or industry – only purely private use is excluded.

• Step 2 – Conduct risk assessment:
  Assign your AI applications to the four risk levels of the AI Acts, from harmless to unacceptable. This helps you identify which obligations specifically apply to you.

• Step 3 – Ensure AI competence:
  Plan training measures for your employees according to Article 4 of the AI Regulation – as an online course, face-to-face training, or self-study, suitable for your team's knowledge level and application area. This not only fulfills the legal requirement: Trained employees recognize faulty AI results, use the systems more effectively, and can better assess where use makes sense.

• Step 4 – Seek legal advice:
  Especially for self-developed AI systems and in questions regarding data protection, copyright, and industry-specific regulations, determine whether you need legal support.

• Step 5 – Regularly review legal situation: Regulation is evolving dynamically. Follow current developments and continuously adapt your processes to remain compliant.

You will find more information on the AI Compass theme "Law and Regulation" in our download portal.