Verdict: binding soon, not noise. The EU AI Act's transparency duties require providers to machine-mark AI-generated audio, image, video and text, and deployers to visibly disclose deepfakes and AI-written text on public-interest topics. The European Commission's framework schedules these obligations for 2026 — imminent as of mid-year. Prioritise the machine-readable mark at generation.
Verdict: treat it as binding soon. Under the European Commission's risk-based AI Act, your feature is high-risk if it is a safety component of a regulated product or falls in a listed use like hiring, credit, or biometrics. If so, you owe risk management, data governance, logging, documentation, human oversight, and robustness.
Use the NIST AI RMF as a control checklist, not a compliance form. It's voluntary, but procurement and auditors increasingly treat it as the baseline. Work MAP and MEASURE first — inventory context, then run real evaluations — before claiming GOVERN and MANAGE. The generative profile lists 12 risks and 200-plus suggested actions: prioritise them, don't self-attest.
Verdict: the EU AI Act's general-purpose-AI obligations are binding now on model providers (since 2 August 2025), and the transparency and deployer duties your team owns turn binding 2 August 2026. If you only call an API you're a deployer; fine-tuning can make you an accidental provider inheriting documentation and copyright duties. Act before August.
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