APREX · EST. 2026
On 10 June 2026, the European Commission published its final guidance on the marking and labelling of AI-generated content — the so-called "Code of Practice" under the EU AI Act. The document spells out what awaits businesses across the EEA, including Norway, when the legally binding requirements enter into force in a matter of weeks.
What Does the Law Require?
At the heart of the regulation is Article 50 of the EU AI Act, which obliges what the EU calls "deployers" — that is, businesses that deploy AI systems — to clearly inform users when they are encountering artificially generated or manipulated content. The requirements are broader than many expect.
In addition, providers of generative AI models are required to embed machine-readable signatures — so-called watermarks — in audio, images, video, and text, so that content can be traced back to an AI source.
Standardised EU Icons and Visible Labels
The Commission has developed a set of standardised "EU AI Icons" that businesses may voluntarily integrate to flag synthetic content. While the use of these icons is optional, the requirement for clear and prominent labelling is not. A small footnote buried in terms and conditions will not suffice — labelling must be visible and presented at the moment the user encounters the content, according to the Commission's guidance.
"Europeans have the right to know whether what they see, hear, or read has been created or altered by AI — especially when such content can shape public debate." — Henna Virkkunen, EU Vice-President for Technological Sovereignty
Sceptics Warn of Weaknesses
Not everyone is convinced the measures are robust enough. Experts who participated in the IBA Annual Conference have highlighted what they see as a fundamental weakness in the technology underpinning the regulation: watermarks can, they argue, be removed relatively easily, and those who deliberately seek to spread false AI-generated content will not voluntarily label it in any case. These concerns have not yet been officially addressed by the Commission, and it remains to be seen how enforcement will work in practice.
Substantial Fines for Violations
The consequences of non-compliance are significant. Breaches of the transparency requirements in the AI Act can trigger administrative fines of up to €15 million, or three percent of the company's total global annual turnover — whichever is higher. For other, more serious violations of the law, fines can rise to €35 million or seven percent of global turnover.
What Must Norwegian Businesses Do Now?
Because Norway is part of the EEA, the EU AI Act's requirements will in practice apply to Norwegian businesses that target the European market. This means that companies at home have very limited time to adapt.
The Commission recommends that businesses begin with a systematic review of all workflows in which AI is used to produce or modify content — spanning everything from marketing and customer service to internal training. Clear and prominent labelling mechanisms must then be implemented. Documentation is also required: system purpose, training data summaries, performance metrics, and ongoing monitoring procedures must be available for presentation to supervisory authorities.
A public list of businesses that have signed the voluntary Code of Practice is expected to be published in July 2026 — the month before the requirements become law.
Timeline to Entry into Force
For Norwegian businesses that have not yet begun their compliance work, the window is narrow — but there is still time to act.