Legal edition
This week is all about rules and risk: the EU transparency rules are about to start, and scammers are becoming ever more convincing with AI.
EU AI Act: transparency rules start on 2 August
The first hard obligations are coming, and the fines are steep.
On 2 August 2026, the main rules of the EU AI Act take effect. This includes the transparency duty in Article 50. If you use an AI system that talks with people, you must make that clear. For watermarks on existing AI text, images and audio, there is a transition period until 2 December 2026. The toughest rules for high-risk AI have been pushed back to late 2027, under the Digital Omnibus agreement. Fines for banned practices can reach 35 million euros or 7 percent of worldwide annual turnover.
Background for subscribersKeep three dates in mind, for yourself and your organisation: 2 August 2026 (transparency and start of enforcement), 2 December 2026 (end of the transition period for watermarks on existing generative AI), and late 2027 (the toughest high-risk rules). Are you an in-house lawyer? Then this is your file: soon you will be advising your employer yourself on which AI uses fall under which rule. Think especially of recruitment and selection, since that is already high-risk.
Recruitment AI already falls under the high-risk rules
AI used for recruitment and selection has fallen under the high-risk category of the EU AI Act since February 2025. This brings requirements around transparency, data quality and human oversight. In 2026, 78 percent of Dutch recruiters use AI tools. Violations can lead to fines of up to 15 million euros or 3 percent of worldwide annual turnover.
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