Want the Presumption of Conformity? You Have Until July 22 to Sign the Code of Practice

Everyone planning for the EU AI Act is circling August 2, 2026, the date the Article 50 transparency obligations become enforceable. Fair enough. But there's an earlier date that barely anyone is talking about, and it carries a real legal benefit you can only claim if you act in time: July 22, 2026.

That's the cutoff to be on the published list of initial signatories to the Code of Practice on transparency of AI-generated content. Miss it and you can still comply with Article 50, but you forfeit the cleanest, cheapest way to prove you do.

The date almost nobody is watching

The AI Office published the final Code of Practice on marking and labelling AI content on June 10, 2026. To be included in the first published list of signatories, providers and deployers must submit their completed signing form by July 22, 2026, at 18:00 CEST. The list is then made public in July, ahead of the August 2 entry into application.

Being on that first list isn't just vanity. It's a public, timestamped signal that you committed to the Commission's own transparency standard before the obligations even took effect. For a company that sells to enterprises or cares about regulatory reputation, that's worth having.

What "presumption of conformity" actually means

Here's the part that makes the date matter. Companies that sign the Code and implement its measures get a presumption of conformity with the Article 50 obligations it covers.

In plain terms: instead of having to construct your own argument that your marking and labelling approach satisfies the law, you point to the Code. The burden flips. A regulator starts from the assumption that you're compliant because you followed the agreed standard, and would have to rebut that rather than you having to prove it from scratch.

Who can sign

The Code is open to providers and deployers of generative AI systems subject to the obligations in Article 50(2) and/or Article 50(4). That means:

• Providers who build generative AI systems capable of producing synthetic audio, image, video, or text — including general-purpose AI systems.
• Deployers who use generative AI to produce and publish content, particularly deepfakes and AI-generated text on matters of public interest.

If you're not sure which you are, that distinction drives a lot of your obligations, so it's worth getting right. Our deployer vs provider guide walks through it.

Should you sign by July 22?

For most companies building or deploying generative AI for the EU market, the honest answer is yes, and the reasoning is the same as for any presumption-of-conformity mechanism. You have to comply with Article 50 either way. The Code is the Commission's own blueprint for how. Signing converts a vague obligation into a defined checklist and hands you a legal presumption on top. The cost is committing to measures you largely have to implement regardless.

The case against signing is narrow. If your marking approach is genuinely more rigorous than the Code, or you have technical constraints the Code doesn't fit, you might document your own compliance instead. But you'd be giving up the presumption to do it, so the bar for "our own way is better" should be high.

How to sign

The AI Office published the signing form and instructions alongside the final Code on the Commission's digital strategy site. The practical sequence:

• Confirm whether you're a provider, deployer, or both, and which Article 50 obligations apply to you.
• Review the Code's measures and make sure you can actually implement them — signing is a commitment, not a checkbox.
• Complete and submit the signing form before July 22, 2026, 18:00 CEST.
• Build the implementation work into your August 2 readiness plan. Read our breakdown of what the Code asks for before you commit.

The deadline isn't loud, which is exactly why it's worth flagging. A month from now there will be a published list of companies that signalled early compliance, and a much longer list of companies that didn't notice the date. It costs very little to be on the right one.