European Commission launches consultation on AI transparency obligations under the EU AI Act

The European Commission launched a public consultation on draft guidelines related to the transparency obligations established under the European Union’s AI Act. The initiative aims to clarify how providers and deployers of artificial intelligence systems must comply with requirements designed to ensure that users are informed when interacting with AI-generated or AI-manipulated content.

The draft guidelines address obligations applicable to AI systems capable of generating synthetic media, including deepfakes, as well as systems involving biometric categorization and emotion recognition technologies. The proposal also outlines expectations regarding the use of machine-readable markings and disclosures intended to identify AI-generated content and improve transparency for users and regulators.

The consultation seeks input from industry stakeholders, developers, public authorities, academia, and civil society before the final adoption of the guidelines. In parallel, the European Commission is supporting the development of a voluntary Code of Practice that may help organizations demonstrate compliance with transparency obligations under the AI Act.

The initiative forms part of the broader implementation framework of the EU AI Act and reflects increasing regulatory focus on mitigating risks related to misinformation, synthetic content, and the responsible deployment of artificial intelligence technologies across the European market.

This represents a medium-impact regulatory development, as the European Commission’s draft guidelines introduce important compliance and transparency obligations under the EU AI Act without creating entirely new categories of prohibited AI systems or replacing existing digital regulatory frameworks.

The impact is considered moderate because the initiative primarily affects operational transparency, disclosure practices, content labeling obligations, and compliance procedures for providers and deployers of artificial intelligence systems operating in the European Union.

Although the draft guidelines do not establish new technical standards for telecommunications, RF, EMC, or hardware certification, they create substantial governance, compliance, cybersecurity, and reputational implications for companies developing or distributing AI-generated content and generative AI technologies.

The proposal also increases regulatory expectations regarding the identification of AI-generated content, including deepfakes and biometric-related AI applications, which may require updates to internal compliance systems, content moderation practices, and digital transparency mechanisms.

Key reasons for medium impact:

• Introduces transparency obligations for AI-generated and AI-manipulated content
• Requires disclosures for deepfakes and certain biometric AI systems
• Encourages implementation of machine-readable labeling mechanisms
• Creates additional compliance expectations for AI providers and deployers
• May require updates to platform governance and content moderation systems
• Strengthens regulatory oversight of generative AI applications
• Increases cybersecurity and misinformation-related compliance considerations
• Impacts digital platforms, AI developers, and organizations operating in the EU market
• Does not impose new RF, EMC, telecom, or hardware technical standards

Who?

• European Commission
• AI system providers and deployers
• Generative AI developers
• Digital platforms and online service providers
• Media and content distribution companies
• Compliance and regulatory affairs teams
• Cybersecurity and digital governance professionals
• Organizations operating AI systems within the EU market

Conclusion

The European Commission’s consultation on AI transparency obligations represents a significant step in the operational implementation of the EU AI Act, particularly regarding disclosure obligations for AI-generated content, deepfakes, and biometric AI applications.

While the initiative does not introduce new hardware or telecom technical certification requirements, it creates meaningful compliance and governance implications for organizations developing, deploying, or distributing AI technologies in Europe.

As a result, this qualifies as a medium-impact regulatory development, particularly for companies involved in generative AI, digital content platforms, cybersecurity governance, and AI compliance management.