AI Act: Transparency Obligations from August 2026
New AI transparency obligations will apply from August 2, 2026. Here is how trade businesses can prepare their communications and processes in good time.
New transparency obligations for the use of artificial intelligence will apply from August 2, 2026. For trade businesses, this primarily means greater certainty in customer communications: businesses that identify where AI is being used today can prepare the necessary notices in good time and avoid rushed changes shortly before the deadline.
Facts and Analysis
The relevant provisions are the transparency obligations under Article 50 of the European AI Act. In particular, companies must disclose when people are interacting with AI systems. Certain artificially generated content must also be made transparent.
For day-to-day operations, two questions are therefore crucial: Where do people communicate directly with an AI system? And where is content created with the help of artificial intelligence? The answers may differ from one business to another. It is therefore not enough to search only for software explicitly labelled as “AI.” Individual functions within existing applications and communication channels should also be examined.
One possible point of contact is a digital assistant that receives enquiries. Automatically generated text, images, or other content should also be reviewed to determine whether the new transparency obligations apply. Whether a notice is required in a specific case must be assessed based on the application actually being used and the content concerned.
The practical challenge lies less in providing a single notice than in establishing a reliable process. New software features are introduced, responsibilities change, and content appears across different channels. Without a clear overview, a business may be aware that AI is being used but still forget the required label elsewhere.
Structured documentation helps prevent this. Businesses that already maintain their GoBD process documentation will be familiar with the basic principle: a process should not only work but also be described in a traceable way. A separate, concise overview can be created for AI transparency.
What Does This Mean for Trade Business Owners?
Trade business owners must first gain a clear overview of how AI is used within their own business. This includes not only central software systems but also applications that employees independently use for texts, customer responses, or other content.
Points of contact with customers, prospective customers, and other external parties are especially relevant. If an AI system is used at these points, the business should examine how the interaction can be disclosed clearly. For certain artificially generated content, the corresponding question is how its origin can be identified in an understandable way.
This is also an organisational task. Who may publish AI-generated content? Who reviews new features? Who ensures that notices remain permanently visible? Similar questions arise with other digital obligations, such as time tracking in the skilled trades: technology alone is not enough when responsibilities and processes remain unclear.
Document storage also deserves attention. Review results, approvals, and the wording of notices should be stored in a way that makes them easy to find later. The article on audit-proof archiving provides guidance, although the specific arrangements for AI processes must be defined separately.
Recommended Actions
Use this compact four-step checklist as your practical starting point:
Identify AI use: List all systems and functions through which employees use AI or external parties come into contact with it.
Review points of contact: Mark where people interact with an AI system and where artificially generated content is used.
Define notices and responsibilities: Determine how transparency will be provided, who approves implementation, and who monitors changes.
Schedule reviews: Review the overview regularly and whenever new software, features, or communication channels are introduced.
Start with the applications used directly in customer communications. This is usually where potential transparency issues can be identified most quickly. The Deutsche Handwerks Zeitung is the underlying source for the deadline and the obligations described.
FAQ
When do the new transparency obligations take effect?
The transparency obligations under Article 50 of the European AI Act will apply from August 2, 2026.
What must companies generally disclose?
In particular, companies must make it transparent when people are interacting with AI systems. Certain artificially generated content must also be identifiable as such.
What should a trade business do now?
The business should identify its AI applications, review external points of contact, and appoint people responsible for notices, approvals, and documentation. This will create a traceable process by the deadline.
Frequently asked questions
The transparency obligations under Article 50 of the European AI Act will apply from August 2, 2026.
In particular, they must disclose when people are interacting with AI systems or are exposed to certain artificially generated content.
They should identify the AI systems they use, review the relevant points of contact, and establish clear processes for notices, approvals, and documentation.