Who the Commission is actually chasing
The Commission’s enforcement page, last updated 24 August 2026, says the AI Office enforces the rules for providers of general-purpose AI models, for AI systems built by the same provider (or group) as the underlying model, and for AI systems inside designated very large platforms or search engines. National competent authorities enforce the rules for other AI systems.
That same page opens a complaints channel “for downstream providers using general-purpose AI models”: providers of an AI system that contains an integrated GPAI model from another provider, about Articles 53 to 55. The Commission is treating the API caller as downstream, and the model supplier as the one carrying those articles.
What changed on 2 August 2026
| Stack | When the duty started | When fines can land |
|---|---|---|
| GPAI model providers (Chapter V) | 2 August 2025. Models already on the market before that date have until 2 August 2027. | 2 August 2026. The Commission’s GPAI guidelines page says enforcement powers, including fines, enter then. |
| Article 50 transparency (your chatbot / labels) | 2 August 2026 | Same day, with a narrow 2 December 2026 grace only for Article 50(2) machine-readable marks on generative systems already on the market before 2 August. |
| Annex III high-risk systems | 2 December 2027 | Not this quarter. Digital Omnibus moved this. A support chatbot is not this stack. |
The AI Act Service Desk matches: from 2 August 2026, prohibited practices, transparency requirements, and GPAI model rules are enforceable. The Commission’s AI Act overview lists a 31 July 2026 press release titled “Commission starts enforcing AI Act rules and new transparency requirements on 2 August.”
When you would become a GPAI provider
The Commission’s GPAI provider guidelines (obligations in application since 2 August 2025) say they help actors decide whether the obligations apply. One published point: only those making significant modifications to AI models need to comply as GPAI providers, not those making minor changes.
GPAI providers, not API callers, must keep technical documentation for the AI Office, give documentation to downstream system providers, run a Union copyright policy, and publish a training-content summary. Systemic-risk models have extra Article 55 duties. Filings go through EU SEND.
If you trained your own general-purpose model, or you significantly modified one, stop using this page as the answer. That is a $149 brief or counsel, not a checklist.
What you still owe this week
The Article 50 FAQ (updated 24 July 2026) defines an AI system provider as the person who develops a system, or has it developed, and places it on the EU market or puts it into service under their own name or trademark. A US, Canadian, or UK HQ does not take you out if the output is used in the EU.
- If people talk to your in-product assistant, Article 50(1) requires a clear, distinguishable notice from the first interaction, unless it is obvious to a reasonably well-informed person. The FAQ says interpret that exception restrictively.
- Put the notice in the product: “This is an AI assistant. You are not speaking with a person.” A privacy-policy line is not enough.
- If you generate synthetic audio, image, video, or text, Article 50(2) machine-readable marking is a provider duty. Systems already on the market before 2 August get until 2 December. Later launches do not.
- National market surveillance authorities handle most Article 50 cases. The FAQ says the AI Office steps in only when the same entity provides the system and the GPAI model, or the system sits inside a designated VLOP or VLOSE.
Do this in seven days
- Do not open a GPAI Code of Practice workstream unless you actually provide a general-purpose model.
- Ship the in-product chatbot notice if it is not already live.
- Inventory generative outputs. Open a 2 December marking ticket only if the system was on the market before 2 August. If you launched on or after that date, the mark is already due.
- If a vendor contract is up, ask for the Article 53 downstream documentation the model provider already owes you. That is their filing, not yours.
Buy the checklist
The $29 Article 50 Ship Checklist is the print-and-tick page for the duty that is actually live: inventory, the notice line, deepfake labels, and the 2 December mark. A $149 Money Brief is the right buy if you fine-tuned a model and need a classification call.
Sources
Fetched 28 August 2026 (PT). No invented dates or quotes.
- European Commission, “The enforcement framework of the AI Act,” last update 24 August 2026. digital-strategy.ec.europa.eu/en/policies/enforcement-ai-act
- European Commission, “AI Act,” last update 3 August 2026. digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai
- European Commission, “Guidelines for providers of general-purpose AI models.” digital-strategy.ec.europa.eu/en/policies/guidelines-gpai-providers
- European Commission, Article 50 FAQ, last update 24 July 2026. Transparency obligations under Article 50 of the AI Act
- AI Act Service Desk, “When does enforcement start?” ai-act-service-desk.ec.europa.eu