AI Act: transparency obligations applicable from August 2, 2026 for Italian companies

Article 50(1) requires providers to inform natural persons when they interact with an AI system. The information must be clear and timely, preferably placed at the start of the interaction or within the user interface. This obligation coordinates with the information notice provided under Art. 13 GDPR for personal data processing.

For synthetic content such as audio, video, or images, Article 50(2) provides for a technical marking obligation, while paragraph 8 relates to the adoption of implementing acts by the European Commission to define its requirements. Companies must ensure that produced files are machine-readable and contain metadata identifying their artificial origin. These acts will define specific technical solutions and marking standards.

In the case of deepfakes, the transparency obligation is provided by paragraph 4 of Article 50 to prevent disinformation. Furthermore, Article 50 provides specific obligations for emotion recognition and biometric categorization systems (paragraph 3). Companies must explicitly declare that the content has been artificially generated or manipulated, except for limited cases of creative, satirical, artistic, or fictional works.

Based on Bill A.C. 1914, currently undergoing parliamentary process, Italy intends to designate AgID and the National Cybersecurity Agency (ACN) as supervisory authorities. These bodies would have inspection powers to verify that companies have correctly implemented transparency mechanisms. Compliance concerns not only the user interface, but also log retention and technical documentation of the systems used.

The AI Act provides for sanctions up to 15 million euros or 3% of total worldwide annual turnover for the preceding financial year. However, for SMEs and start-ups, Art. 99(6) states that the maximum penalty limit corresponds to the lower value between the fixed amount and the turnover percentage. The enforcement of digital regulations reflects increasing severity, with sanctions that can be significant.

Navigating AI compliance requires advanced tools like edit.legal, which offers access to over 1 million verified documents and 21 practice areas. Thanks to the MCP server and the Microsoft Word add-in, lawyers can securely integrate AI into their workflow, leveraging a European infrastructure compliant with the GDPR. Internal analysis of user queries confirms the need for automated legal sources to manage these new deadlines.