EU AI Act Compliance Checklist 2026
10 steps to support you in implementing the transparency obligations under Art. 50 EU AI Act – from inventory to ongoing monitoring. Tick items off interactively or download the PDF.
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The 10-Point Checklist
Organized into four phases. Tick off what you have already implemented – your progress is shown above.
Inventory
Transparency Obligations
Evidence & Processes
Ongoing Operations
Note: Under the AI Omnibus package, existing systems benefit from a transition period until 2 December 2026 – but only for the machine-readable provider marking under Art. 50(2). All other transparency obligations apply from 2 August 2026.
Frequently Asked Questions about the EU AI Act Checklist
Who does Art. 50 EU AI Act apply to?
Art. 50 addresses providers and deployers of certain AI systems – i.e. companies that develop or use AI systems whose outputs reach people in the EU. It particularly covers chatbots, generative AI content (images, videos, audio, text), emotion recognition and biometric categorization. The company's location is irrelevant – what matters is the EU nexus.
What happens in case of violations of Art. 50?
Under Art. 99(4)(g), fines of up to €15 million or 3% of worldwide annual turnover apply – whichever is higher. For SMEs and start-ups, the AI Omnibus package caps fines at the lower of the two amounts. The transparency obligations apply from 2 August 2026.
Does every ChatGPT text need to be labeled?
No. The labeling obligation under Art. 50(4) only applies to published AI texts that inform the public on matters of public interest. It also does not apply where a human review takes place and a natural or legal person holds editorial responsibility. Internal documents, marketing copy or editorially reviewed content are therefore generally not affected.
What is the Code of Practice on Transparency?
The Code of Practice on Transparency of AI-Generated Content is a voluntary framework by the European Commission, final since 10 June 2026. It specifies how to implement the transparency obligations under Art. 50 – including standardized EU AI icons for labeling AI content – and supports companies in putting the requirements into practice.
Can competitors send cease-and-desist letters for missing AI labels?
In Germany this is a realistic risk – often faster than an authority procedure. The Art. 50 labelling duty is likely to qualify as a market-conduct rule under § 3a UWG (German unfair-competition law); competitors and consumer associations could then issue cease-and-desist letters (injunction, costs). The German competition authority (Wettbewerbszentrale) already published guidance on this in early 2026. Documented labelling or a recorded exemption proof protects you on both fronts.
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This checklist is for general information purposes only and does not constitute legal advice. AIActify supports you in implementing the transparency obligations but does not replace an individual legal assessment. For binding advice, please consult a specialized law firm.