AI Act · India · Compliance · Article 50 · EU Market
EU AI Act: What Indian Companies Must Do Now
The EU AI Act’s enforcement and transparency phase has begun. Key compliance steps for Indian companies supplying AI systems or services in Europe.
2 August 2026 marks a decisive shift in the implementation of the EU AI Act. For Indian and other non-EU companies serving European customers, the key issue is no longer whether the regulation may apply, but which obligations apply to their systems, content and operations now.
The EU Artificial Intelligence Act has entered a new enforcement phase.
From 2 August 2026, the European Commission’s AI Office and national authorities begin enforcing the provisions of the AI Act that are already applicable. At the same time, the transparency obligations under Article 50 take effect.
This is not the moment when every AI Act requirement becomes applicable. The rules are being introduced through a phased timeline. Nevertheless, companies that provide AI products, operate AI-enabled services or distribute AI-generated content in Europe now face a more immediate compliance environment.
The AI Act reaches beyond the European Union
An Indian company does not need to have a registered office in Europe to fall within the scope of the AI Act.
Under Article 2 of Regulation (EU) 2024/1689, the regulation may apply to:
providers placing AI systems or general-purpose AI models on the EU market;
providers and deployers established outside the EU when the output of their AI system is used in the Union;
importers, distributors and certain product manufacturers;
non-EU companies providing access to AI systems in Europe through an application, cloud service, API or other interface.
For Indian companies, the practical trigger may therefore be an EU customer, European-facing platform, EU distribution partner or the foreseeable use of AI outputs within Europe.
Merely describing a system as being “developed in India” or “operated outside Europe” does not remove it from the regulation’s territorial scope.
What became applicable on 2 August 2026?
The most visible development is the application of Article 50 of the AI Act.
Article 50 creates different duties for providers and deployers of AI systems.
1. AI interaction disclosure
Providers of AI systems intended to interact directly with people must generally ensure that individuals are informed that they are interacting with AI, unless this is already obvious to a reasonably informed and observant person.
This may affect:
customer-service chatbots;
AI assistants;
conversational sales tools;
AI agents communicating with customers;
AI-enabled legal, financial or healthcare interfaces.
A small notice hidden in general terms and conditions may not provide sufficiently effective disclosure. Transparency should be integrated into the user experience.
2. Machine-readable marking of synthetic content
Providers of systems generating or manipulating text, images, audio or video must, subject to the statutory exceptions, enable their outputs to be identified in a machine-readable format as artificially generated or manipulated.
The technical solution must be effective, interoperable, robust and reliable to the extent technically feasible.
Following the Digital Omnibus on AI — Regulation (EU) 2026/1744, certain generative AI systems already placed on the market before 2 August 2026 benefit from a limited transition period until 2 December 2026 for the Article 50(2) marking and detection requirement. This is a targeted transition, not a general exemption from Article 50.
3. Deepfake and synthetic-media disclosure
Deployers must disclose when image, audio or video content constitutes a deepfake.
This is particularly relevant to:
advertising campaigns;
synthetic brand ambassadors;
AI-generated executive videos;
political or public-affairs communications;
simulated voices;
manipulated interviews or testimonials.
The disclosure must be clear, distinguishable and provided no later than the first exposure to the relevant content.
4. Public-interest publications
AI-generated or manipulated text published to inform the public on matters of public interest may also require disclosure.
However, Article 50 provides an important exception where the content has undergone human review or editorial control and a natural or legal person holds editorial responsibility for its publication.
For legal, policy and regulatory publishers, the practical question is therefore not simply whether AI was used. The organisation should be able to demonstrate meaningful human review, editorial responsibility and control over the final publication.
The European Commission’s Article 50 transparency guidelines provide further operational guidance for providers and deployers.
Existing obligations have not disappeared
Article 50 is only one part of the compliance picture.
Prohibited AI practices and the AI literacy obligation have applied since 2 February 2025. Obligations concerning general-purpose AI models and the EU governance framework have applied since 2 August 2025.
From 2 August 2026, enforcement begins at EU and national level for applicable requirements concerning:
prohibited AI practices;
AI literacy;
general-purpose AI models;
Article 50 transparency;
relevant governance and innovation-support provisions.
The rules for high-risk systems listed in Annex III are now scheduled to apply from 2 December 2027, while the requirements for high-risk AI embedded in certain regulated products under Annex I are scheduled from 2 August 2028. These changes were introduced by the Digital Omnibus on AI.
The phased timeline should not be interpreted as permission to postpone the entire compliance programme. Classification, role allocation and evidence preparation need to take place before the relevant obligations become enforceable.
What Indian companies should do now
1. Map the EU connection
Identify where AI systems, APIs, outputs, customers, distributors or group companies connect with the European market.
2. Determine the company’s legal role
Establish whether the organisation acts as a provider, deployer, importer, distributor, product manufacturer or GPAI model provider. One company may hold several roles simultaneously.
3. Review every human-facing AI interface
Check chatbots, AI agents and automated customer interactions. Determine where disclosure is required and whether it is sufficiently clear.
4. Audit synthetic-content workflows
Review how AI-generated text, images, audio and video are created, marked, approved and published. Contractual terms with marketing agencies and content suppliers should allocate responsibility for Article 50 compliance.
5. Create an evidence file
Maintain records of:
system classification;
intended purpose;
applicable AI Act provisions;
disclosure language;
machine-readable marking;
human-review procedures;
editorial approval;
staff AI literacy measures;
technical and contractual controls.
The regulator’s question may not be limited to whether a notice exists. The organisation may need to demonstrate how the compliance decision was reached and implemented.
The strategic point
For Indian technology companies, AI Act compliance is becoming part of EU market access.
European customers, investors and procurement authorities are increasingly likely to request evidence showing how an AI system has been classified, governed and monitored. A defensible compliance position can therefore support not only risk management, but also contracting, investment and commercial credibility.
CORVUS AI supports organisations in translating the AI Act into practical system classification, transparency controls, evidence packages and market-entry decisions.
Complex law. Clear action.
This publication is provided for general informational purposes only. It does not constitute legal advice and should not be relied upon as a substitute for advice based on the specific facts, technology, contractual structure and jurisdictions involved.
