Transparency obligations: what you have to disclose, and when
People must know when they are talking to a machine, and machine-made content has to be recognizable as such. This is the obligation set with the nearest deadline — 2 December 2026.
Last reviewed:
Sound familiar?
- Your chatbot never says it is a bot, because product decided it felt friendlier that way.
- Marketing publishes AI-generated images and text with no marking and no internal rule.
- Nobody owns the question of what a disclosure has to say, where it appears, or in which language.
- The deadline is treated as a legal problem, while every change to make happen sits in product and content.
What we do
Touchpoint inventory
Every place where users meet AI output: chat, voice, generated media, recommendations, automated correspondence.
Disclosure design
Wording and placement that satisfies the duty without ruining the interface — reviewed together with your product people, not imposed on them.
Content marking
How generated or manipulated media gets labelled and what has to survive export, re-upload and downstream reuse.
Deadline plan
A dated list of changes with owners, so 2 December 2026 arrives as a checkpoint and not as a fire drill.
Questions we get
Is a line in the terms of service enough?
No. The disclosure has to reach the person in the moment of the interaction, in clear language. Burying it in a document nobody opens does not discharge the duty.
Do we need to label AI-assisted drafts a human then edited?
It depends on how much of the published output is machine-generated and on the type of content. We draw the line per content type and write the rule down so your team can apply it without asking legal every time.
What if we are not sure the deadline applies to us?
Then that is the first thing we settle. The transparency duties attach to specific situations, and knowing you are out of scope is worth as much as knowing you are in it.
Tell us what's running in production.
We'll tell you what we'd check first — and what we wouldn't bother with.
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