EU AI Act: Article 50, and the De...

EU AI Act: Article 50, and the Deadline in December

AI
Project Cognivora by Kris Cordier
S1 · E6
Sep 24, 2026
20:34

Episode notes

A company of 140 people in Hamburg ran a campaign fronted by a presenter talking to camera about floor coatings. There is no presenter. She was generated. In June that was lawful. The campaign is still running, and in August the rules changed. What arrived was not an inspector, but a letter from a competitor's lawyer.

Article 50 of the EU AI Act has applied since 2 August 2026. Four duties in one article, landing on different people: 1 and 2 bind providers, 3 and 4 bind deployers, and 5 governs how and when you say any of it. Your vendor's watermark discharges your vendor's duty and does nothing for yours.

Then the date almost everybody has wrong. The transitional period to 2 December 2026 is not in Article 50. The Digital Omnibus put it in Article 111(4); it covers only the marking in Article 50(2), and only for systems already on the market before 2 August 2026.

Also here: what the Commission guidelines of 20 July 2026 did to the word "obvious"; why a person who never existed is still a deep fake under Article 3(60) and a dragon is not; what "human review or editorial control" has to mean; the research that strips a watermark for fifty dollars; Article 99(4)(g) and the flip in 99(6) for smaller companies; and not one fine we could find.

Two hosts, twenty minutes, every article number checked so you can check us.

DISCLOSURE: Maya and Sam are AI-generated voices. They are not real people and this is not a recording of a conversation that took place. The music is also generated. The script was written and edited by a human, Kris Cordier, who carries editorial responsibility for it.

This episode is information, not legal advice. Before you decide no disclosure is needed, talk to a lawyer.

CHAPTERS

0:00 These are AI voices, and why we say so first

1:40 Welcome to Project Cognivora

2:20 Four duties, and the question that sorts them

3:28 Tell people it is a machine, and the escape hatch

4:51 Mark what the machine makes, and whose job that is

6:21 The deadline that is not in Article 50

7:46 Emotion recognition, and where Article 5 got there first

9:14 Deep fakes, dragons, and an objective test

11:25 Public-interest text, and what editorial control means

12:57 Marking is engineering, and the watermark washes off

14:09 The Code of Practice, and what signing it buys you

15:02 Article 99, and the flip that helps small companies

16:27 Nine without a caveat, and no fine we could find

17:43 Ninety seconds: five things to do on Monday

19:09 What happened in Hamburg, and who to send this to

SOURCES

Regulation (EU) 2024/1689: https://eur-lex.europa.eu/eli/reg/2024/1689/oj

Regulation (EU) 2026/1744, the Digital Omnibus: https://eur-lex.europa.eu/eli/reg/2026/1744/oj

Commission guidelines, C(2026) 5054 final, 20 July 2026: https://digital-strategy.ec.europa.eu/en/library/guidelines-transparency-obligations-providers-and-deployers-ai-systems

Commission questions and answers: https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act

https://www.project-cognivora.com