# EU labelling code counts as adequate for deployers who sign it

The Commission backed the code on 8 July and the AI Board on 9 July, and 192 entries sit on the Section 2 list.

Published 11 November 2026 by EuGFA in The Briefing. Interests: Policy.

## What happened

The European Commission concluded on 8 July 2026 that the Code of Practice on Transparency of AI-generated Content adequately covers Articles 50(2), (4) and (5) of the AI Act. The AI Board adopted its own adequacy assessment on 9 July. Adherence to the code is not conclusive evidence of compliance.

Section 1 of the code is written for providers of generative systems and covers machine-readable marking. Section 2 is written for deployers and covers labelling, with a specific regime for artistic, creative, satirical and fictional works. The Commission's list shows 95 Section 1 and 192 Section 2 signatories, and the code remains open for signature.

## Why it matters

Article 50(4), which has applied since 2 August 2026, puts the deepfake labelling duty on deployers. A production company that publishes generated footage which could appear authentic sits on that side. If it signs Section 2, it can rely on the code's measures to show compliance. A company that does not sign must show market surveillance authorities that its own measures are adequate.

## Still open

As of 11 November 2026, the Commission's signatory list was last updated on 24 September, so later signatories may be missing. The Commission pages checked give no closing date for signatures.

## For your film

A producer can download the signatory form from the Commission's "How to sign" page. It should be signed by a person with authority to bind the signatory and sent to CNECT-AIOFFICE-CODE-OF-PRACTICE-TRANSPARENCY@ec.europa.eu.

## Read further

- [Commission opinion on the assessment of the code](https://digital-strategy.ec.europa.eu/en/library/commission-opinion-assessment-code-practice-transparency-ai-generated-content)
- [Signatory list, European Commission](https://digital-strategy.ec.europa.eu/en/news/strong-backing-code-practice-transparency-ai-generated-content)
- [How to sign the code](https://digital-strategy.ec.europa.eu/en/library/how-sign-code-practice-transparency-ai-generated-content)