On 8 May 2026, the European Commission published draft guidelines on the implementation of the transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act). The draft guidelines describe how the AI Act’s four transparency obligations are intended to apply to (i) interactive AI systems; (ii) providers of AI systems that generate or manipulate synthetic content; (iii) deployers of emotion recognition and biometric categorization systems; and (iv) deployers of deepfakes and AI-generated text on matters of public interest. While non-binding, European Commission guidelines carry considerable practical importance in the application of EU law.

Link to Continue reading the full GT Alert. Continue reading the full GT Alert.

Tags: AI
Photo of Dr. Philip Radlanski Dr. Philip Radlanski

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on matters relating to artificial intelligence (AI), data privacy, and cybersecurity. His work focuses on complex and innovative data-heavy AI

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Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on matters relating to artificial intelligence (AI), data privacy, and cybersecurity. His work focuses on complex and innovative data-heavy AI projects, often with cross-border aspects. He also assists with addressing cybersecurity issues, including data breach incident management and response. He gained strong recognition throughout Europe for his representation in the first German trial against a GDPR fine, in which he was able to achieve a reduction of the multimillion-euro fine by more than 90 percent.

As a driving force behind the firm’s AI practice in Germany, he guides companies through the complex and rapidly evolving regulatory landscape surrounding artificial intelligence — from the EU AI Act and sector-specific requirements to the intersection with data protection and intellectual property law.

With a strong understanding of the technical underpinnings of AI and a practical, business-oriented mindset, Philip is regularly sought after by multinational companies, technology providers, and start-ups developing or deploying AI systems. He advises on all aspects of AI governance — from risk assessments and compliance strategies to drafting internal policies and representing clients before regulatory bodies. Philip also works closely with in-house legal, compliance, and technical teams to promote effective AI oversight, foster privacy-by-design, and drive responsible, future-proof adoption of transformative technologies.

Philip is known for his pragmatic approach, which he was able to further refine through several months of secondments to the legal departments of a leading German internet service provider and an internationally operating online marketplace for food delivery. A further one-year secondment to the Global Privacy & Data Security Group of an international law firm in New York shaped Philip’s understanding of the U.S. market and U.S. clients.

Prior to practicing as an attorney, Philip worked as a research assistant at the University of Regensburg, Germany, and as a visiting tutor at King’s College London, UK. He also worked with the German Federal Film Board, the cybercrime division of the Berlin District Attorney’s Office, and for different international law firms in Berlin, New York, and Sydney.

He is a member of the German Association for the Protection of Intellectual Property and Copyright (GRUR), the International Technology Law Association (ITechLaw), and the Bauhaus Archive.

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Photo of Carsten A. Kociok Carsten A. Kociok

Carsten Kociok is a partner in the Technology, Financial Services and Data Privacy Practice in Berlin and Co-Head of Greenberg Traurig’s global Fintech Group. He advises national and international clients across all industries, including financial services, information technology, artificial intelligence, ecommerce, media, health

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Carsten Kociok is a partner in the Technology, Financial Services and Data Privacy Practice in Berlin and Co-Head of Greenberg Traurig’s global Fintech Group. He advises national and international clients across all industries, including financial services, information technology, artificial intelligence, ecommerce, media, health care, telecoms, retail and real estate, on a wide variety of complex commercial and regulatory matters.

Carsten is a leading technology lawyer, ranked consistently in Band 1 for Fintech Legal in Germany since 2020. He has in-depth and wide-ranging experience in the areas of privacy and cybersecurity, payments law, financial services, e-money products, blockchain technology, and financial and banking regulation, as well as in artificial intelligence regulation – including compliance with the EU AI Act – and the integration of AI technologies into existing software systems.

Carsten regularly assists clients in licensing projects and audit proceedings with financial regulators and advises on the contractual and regulatory aspects of developing, implementing and operating financial technology products and transactions.

On the data privacy side, Carsten counsels clients on complex data-driven business models and regulatory matters, including on international data transfers, data privacy compliance, monetization of data, artificial intelligence, litigation, cybersecurity and data breach response.

Carsten regularly lectures and publishes on various FinTech and data privacy topics. Prior to joining the firm, Carsten worked at Olswang Germany for eight years and in the Capital Transaction Practice Group of an international law firm in New York.

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