BSA’s comments on the first draft of the EU Code of Practice on transparency requirements under Article 50 of the AI Act caution that the proposal risks exceeding the Act’s scope and creating disproportionate technical and operational burdens. The submission calls for clearer role allocation across the AI value chain, flexibility based on technical feasibility and proportionality, and revisions to marking and detection requirements, including excluding software code and avoiding unrealistic standards. Overall, BSA stresses that the Code should enable practical, innovation-friendly implementation while ensuring transparency and legal certainty.