Since 2 August, Article 50 of the AI Act has applied new transparency obligations to certain systems and to content generated or manipulated by AI. But the answer is not simply that “all AI-generated content must carry a label.”

The regulation distinguishes between providers and deployers of AI systems, between types of content, and between contexts of use. Providers of generative systems have machine-readable marking obligations; deployers must inform people in specific cases, such as deepfakes or certain texts on matters of public interest.

There is also a transitional period, until 2 December, for certain marking obligations that apply to generative systems already on the market before 2 August.

It looks like a legal detail. But I believe it reveals something much larger.

Between adopting a regulation and getting an organisation, or a society, to know how to apply it, there is a vast governance space.

And that space is not closed by regulatory compliance alone.

I am currently involved in a consultancy linked to an audit on AI governance and AI Act implementation for international organisations within and beyond Europe. One issue comes up again and again: complying with a rule, and getting an organisation to understand it, build it into its processes and be able to explain it, are different capabilities.

A policy can be approved and still not have become a procedure.
A procedure can exist and still not have reached the people who make decisions.
A transparency obligation can be in force and still be unknown to those it is meant to protect.

This is one of the major challenges of the next phase of AI in Europe: closing the gap between regulation and implementation.

The Regulation itself explains that these obligations aim, among other things, to enable people to recognise when they are interacting with AI or are exposed to certain AI-generated content, and to make informed decisions.

That is why communication does not come at the end of governance. It is part of it.

Europe has spent recent years building the rules for AI. The imminent challenge will be to turn those rules into behaviours, processes and decisions that organisations and citizens can actually understand and use.

Governance begins with the rule. But it only works when it reaches the person.

Where do you think the biggest gap lies today: in knowing the regulation, interpreting it correctly, or turning it into real processes within organisations?

Original (Spanish): europeancommunicationstrategies.com, 17 September 2026