Signing the EU transparency Code of Practice after 27 July 2026

Yes. The Commission's signing FAQ says that "in principle, providers and deployers sign the code at any time, including after 27 July 2026", by submitting the signature form by email. The 27 July 2026, 18:00 CEST deadline was for being on the list of initial signatories published before 2 August 2026. The AI Office still encourages signing by then.

Facts below are from that FAQ, read 2026-10-01. This is not legal advice. For a team that calls a generation API, the useful question is which section applies to you.

What changes if I sign late?

Per the FAQ, Article 50(2), (4) and (5) apply from 2 August 2026. A provider or deployer that has not signed "will need to demonstrate compliance through other means", and market surveillance authorities assess whether those means are adequate. It also says signing is voluntary and that not signing is not itself non-compliance; enforcement concerns the Article 50 obligations, not the absence of adherence to the code.

What does signing late look like in practice?

Per the FAQ, you complete the signature form (DOCX), have a senior executive with authority to bind the organisation sign it, and email it to the AI Office. The signatures are conditional on a positive adequacy assessment by the Commission and the AI Board, and sections are signed whole: Section 1 for providers under Article 50(2), Section 2 for deployers under Article 50(4), or both.

Where do I find the section choice for a video API team?

Which section fits depends on whether you place the AI system on the market under your own name or use someone else's professionally. That comparison is in Section 1 versus Section 2 for a video API team.

What can I do in my pipeline today, signed or not?

Keep the evidence a regulator could ask for. Sume's runs docs say media URLs are durable media.sume.com HTTPS URLs that do not expire, which lets you keep a stable record of what you published. For visible labels on a finished clip, the video captions endpoint takes a public HTTPS video URL and returns a job-backed captioned video. Neither replaces a decision about which section to sign, and the signatures are conditional on a positive adequacy assessment, per the FAQ.