AI Act transparency obligations from 2 August 2026: what must companies in Poland implement?

From 2 August 2026, companies operating in Poland must comply with the transparency duties in Article 50 of the AI Act. The rules concern chatbots, emotion recognition, biometric categorisation, deepfakes and certain texts on matters of public interest. Not every AI-assisted item needs a label, but businesses should implement classification, approval and human-review procedures.

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Which AI Act transparency obligations apply from 2 August 2026?

The AI Act transparency obligations in Poland cover four areas:

• informing users that they are interacting with a chatbot or virtual AI assistant, unless this is obvious;
• machine-readable marking of synthetic outputs by providers of generative systems;
• informing people exposed to emotion-recognition or biometric-categorisation systems;
• visibly disclosing deepfakes and certain AI-generated texts concerning matters of public interest.

For relevant systems placed on the market before 2 August 2026, a limited transition period for technical marking runs until 2 December 2026.

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Must every AI-generated item be labelled?

No. The assessment depends on the material’s realism, the extent of AI intervention and the purpose of publication. Higher-risk examples include realistic product photographs, property visualisations, images of employees or customers, synthetic voices and materials presenting fictional events as genuine.

Corrections to sharpness, exposure or white balance should not automatically trigger disclosure. Adding a person, changing a product’s appearance, generating a new background or depicting an event that never occurred requires a different assessment.

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When must chatbots and AI-assisted texts be disclosed?

A chatbot notice should appear before the interaction or in the first message, rather than only in terms and conditions or a privacy notice.

Not every AI-assisted text requires a label. Disclosure may apply to publications informing the public about matters of public interest. An exemption may be available where the content undergoes genuine human or editorial review and responsibility for publication is assigned.

The business should document who checked the facts, sources and legal basis and who approved the final version.

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How should companies in Poland prepare?

Before 2 August, companies should:

• inventory AI tools used internally and by contractors;
• create a content-assessment matrix and approved disclosures for images, video, voice, chatbots and text;
• retain metadata and file-provenance information;
• introduce substantive, legal, copyright and image-rights checks;
• record approvals and specify in agency contracts who classifies, labels and approves materials.

A breach of Article 50 may result in a fine of up to EUR 15 million or 3% of worldwide annual turnover, whichever is higher. For SMEs, the lower maximum applies.

Foreign companies operating in Poland should supplement global AI policies with a local approval process, an AI-tool register and clear responsibility for Polish-market publications.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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