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

From 2 August 2026, companies doing business in Poland must comply with the transparency duties under Article 50 of the AI Act. The rules cover chatbots, emotion recognition, biometric categorisation, deepfakes and certain texts concerning matters of public interest. Not every AI-assisted item needs a label, but businesses require clear classification, human-review and publication-responsibility procedures.

Which AI Act duties apply from 2 August 2026?

Companies must inform users when they are interacting with an AI system, unless this is obvious. The requirement may apply to website chatbots, virtual customer assistants, recruitment bots, automated messaging advisers and voice-based telephone systems.

Companies using emotion recognition or biometric categorisation must inform the people exposed to them. Visible disclosure may also be required for deepfakes and selected texts on matters of public interest.

Providers of generative systems are responsible for machine-readable marking. For relevant systems placed on the market before 2 August 2026, the transition period runs until 2 December 2026.

Must every AI-generated image or photograph be labelled?

No. The assessment depends on realism, the extent of AI intervention and the publication purpose. Particular attention is required for product images, property and investment visualisations and advertisements presenting fictional situations as genuine.

Corrections to sharpness, exposure or white balance should not automatically trigger disclosure. Adding a person, altering a product, generating a background or depicting a fictional event requires a different assessment.

Must AI-assisted texts be disclosed?

Not every text requires a label. The obligation may cover publications concerning matters of public interest, including law, the economy, public health or security. An exemption may apply where the material undergoes genuine human or editorial review and a person or organisation accepts editorial responsibility for publication.

The company should document who checked the facts, sources and legal basis and approved the final version. A superficial review may not be sufficient.

How should companies doing business in Poland prepare?

Before 2 August, businesses should:

• inventory AI tools used by employees and contractors;
• prepare a content-assessment matrix and approved disclosures;
• retain metadata and file-provenance information;
• introduce substantive, legal, copyright and image-rights checks;
• assign responsibility in contracts and document approval.

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 investors and international companies in Poland should add local approval rules, an AI-tool register and clear publication responsibility to global policies.

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