The Code of Practice the Commission finalized this week covers labeling, watermarking, metadata embedding, and disclosure obligations for any system generating images, video, audio, or text in the EU. Deepfakes (the definition is wide enough to capture most of what generative AI does) must be visibly marked. AI-generated text on matters of public interest must be disclosed unless the content has been through a documented editorial review by a human. Watermarks have to be, in the Commission’s chosen phrase, “robust to common transformations.”
That last word is doing extraordinary lifting. The state of the art in machine-readable watermarking, as of June 2026, survives JPEG compression and modest cropping. It does not survive screenshotting, re-encoding, or anything an actively adversarial editor decides to try. Google’s SynthID is the most-deployed implementation. C2PA Content Credentials are the most-cited standard. Neither is robust in the sense a regulator would actually want once content makes its way to social media, which is the entire reason a regulator wanted watermarking in the first place. The Code does not tell providers which technology to use. It just declares that the technology has to work.
The compliance timeline: Article 50 transparency obligations bind starting August 2, which is eight weeks out. Systems already on the EU market get a transitional period through December 2 to bring themselves into compliance. Systems newly placed on the EU market after August 2 must comply on day one. OpenAI, Anthropic, Google, Meta, and Mistral are all in the first bucket. Any frontier release that ships after August 2 with shoddy or missing watermarking is, technically, a violation from the moment the European user clicks generate.
The watermarking industry is now in an unusually comfortable position. The law guarantees demand. The technology has not yet guaranteed supply. The next twelve months are going to be an interesting case study in what happens when Brussels writes a deadline and the engineering community has to invent the thing being deadlined.