The AI Act marking grace for existing generative systems expires on 2 December 2026

The AI Act grace period ends on 2 December 2026. Providers of generative AI systems placed on the market before 2 August 2026 must meet the Article 50(2) machine-readable marking and detection duty for AI-generated content.

The grace covered systems that were already out in the world. From this date those systems are held to the same marking duty as anything launched since August. The grace ran to 2 December 2026 and covered only systems already on the market when it began.

Providers of generative AI systems on the EU market

Any provider of generative AI systems on the EU market, including small software firms embedding generative features. A generative feature bolted into a larger product still makes its provider a provider.

Bringing older systems up to the marking duty

• List your generative AI systems and the date each was placed on the market.
• Separate those placed before 2 August 2026, which is the group the grace covered.
• Apply machine-readable marking to the content those systems generate.
• Check the marking is detectable, which is the second half of the Article 50(2) duty.
• Record the date each system was brought into line.

The EU AI Act system

Article 50 sits inside the EU AI Act, and the AI Act system covers the Regulation whole.

Verified 19 August 2026.

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