New Year, New Voluntary EU Commission Draft Code on AI Labelling

As the new year begins, the European Commission closed out 2025 by publishing, on 17 December, the first draft Code of Practice on the marking and labelling of AI‑generated content.

The draft Code supports the transparency objectives of the EU AI Act, setting out expectations for AI providers and deployers to identify synthetic content through technical markers, labels, and user‑facing disclosures. These measures are particularly relevant for generative AI systems and general‑purpose AI models.

Importantly, the Code is entirely voluntary. Nevertheless, once finalised, it is expected to influence supervisory practice and shape future enforcement approaches.

As 2026 begins, follow our ongoing regulatory updates. These updates are provided for general information purposes only and do not constitute legal advice. For detailed, matter‑specific advice, please contact us.

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