Regulation: EU AI Act: Provisions already applicable on 2026-10-01 (Art. 5, AI literacy, Art. 4a, GPAI, penalties, Art. 50) and ForgeLM's coverage (aging) (TECH-T10-004) #494

Wave 2 · theme D2-7: Next-release technology updates · highest severity Next release · 1 finding(s) · effort not estimated

Summary

Generative models fine-tuned with ForgeLM and placed on the market as systems after 2 Aug 2026 already fall under Art. 50(2) machine-readable marking, an obligation on the system provider. ForgeLM's docs imply that nothing applies until the high-risk date, a gap in user guidance.

Primary finding

TECH-T10-004 — Regulation: EU AI Act: Provisions already applicable on 2026-10-01 (Art. 5, AI literacy, Art. 4a, GPAI, penalties, Art. 50) and ForgeLM's coverage (aging)

severity Next release

Item. Provisions already applicable on 2026-10-01 (Art. 5, AI literacy, Art. 4a, GPAI, penalties, Art. 50) and ForgeLM's coverage · verdict: aging · urgency: Next release

State in ForgeLM. ForgeLM docs frame the AI Act almost entirely as 'high-risk from August 2026'. No doc in forgelm/, docs/ (outside the roadmap), README or site mentions Art. 50 transparency or machine-readable marking of synthetic output. The GPAI-provider question and the new Art. 5 prohibitions are absent from user docs.

State of the ecosystem on 2026-10-01. Under Art. 113 of Reg. 2024/1689, with points (a) and (c) replaced and (d) added by Reg. 2026/1744 Art. 1(40): - Since 2 Feb 2025: Ch. I-II, i.e. Art. 5 prohibitions and Art. 4 AI literacy. Art. 4 was replaced by 'take measures to support' from 27 Jul 2026, and the new Art. 4a has applied since then. - Since 2 Aug 2025: Ch. III Sec. 4, Ch. V (GPAI), Ch. VII, and Ch. XII penalties except Art. 101, plus Art. 78. - Since 2 Aug 2026 (general date): everything not deferred, including Art. 50 and Art. 101. - Since 27 Jul 2026: Arts 102-110. - Pending: Art. 50(2) for generative systems placed on the market before 2 Aug 2026, by 2 Dec 2026 (new Art. 111(4)); new Art. 5(1)(ba)/(bb) from 2 Dec 2026; legacy GPAI models by 2 Aug 2027 (Art. 111(3)); high-risk on 2 Dec 2027 / 2 Aug 2028. The Commission AI Act page (retrieved today) says the transparency rules apply from August 2026, and lists a Code of Practice on Marking and Labelling of AI-generated Content and Guidelines on transparency obligations.

Impact. Generative models fine-tuned with ForgeLM and placed on the market as systems after 2 Aug 2026 already fall under Art. 50(2) machine-readable marking, an obligation on the system provider. ForgeLM's docs imply that nothing applies until the high-risk date, a gap in user guidance.

Recommendation. Add a dated 'what applies today' table (EN+TR) to the compliance overview, citing Art. 113 as amended by Reg. 2026/1744. Name Art. 50(2) marking, the GPAI-provider test and the Dec 2026 Art. 5 additions as obligations ForgeLM does not discharge. Link the Commission transparency guidelines and the marking code of practice.

Sources.

• Regulation (EU) 2026/1744, Art. 1(5), 1(6), 1(39), 1(40) (2026-07-24)
• Regulation (EU) 2024/1689, Art. 50, Art. 111(3), original Art. 113 (2024-07-12)
• European Commission: AI Act page (transparency rules from August 2026; Code of Practice on Marking and Labelling; trans… (2026-08-03)
• FPF AI Act timeline (2026-07-28 (last updated 2026-08-05))

Acceptance criteria

• Each statement is re-checked against the code at fix time.
• Documentation listed above is corrected in English and in its Turkish mirror in the same PR.
• Every finding in this issue is resolved or explicitly closed with a reason.

_{Found by the October 2026 ForgeLM code and documentation review against commit cab2947. Code links point at that commit; line numbers may have moved since. Finding IDs (CR-…, DOC-…, TECH-…) are stable references for this backlog.}