EU AI Act Article 50 Transparency Obligations: Full Compliance Checklist
Article 50 of Regulation (EU) 2024/1689 is the provision that applies to the widest range of ordinary businesses: not just high-risk AI, but any chatbot, content generator, or emotion/biometric tool. Here is what it actually requires, obligation by obligation.
- In force since 2 August 2026, unaffected by the 2026 Digital Omnibus delay to high-risk rules.
- Applies regardless of whether the AI system is classified as high-risk.
- Four distinct sub-obligations: 50(1) chatbot disclosure, 50(2) synthetic content marking, 50(3) deepfake labelling, 50(4) AI-generated text on matters of public interest.
- Watermarking under 50(2), for systems already on the market before 2 August 2026, has an extended deadline of 2 December 2026.
- Enforced by national market surveillance authorities; fines fall under the general AI Act penalty regime (see the fines guide).
Who Article 50 actually applies to
Article 50 is not limited to high-risk AI systems. It applies to any provider or deployer whose AI system falls into one of four categories: systems that interact directly with people (chatbots), systems that generate synthetic audio/image/video/text content, systems that produce deepfakes, and systems that generate text published for informing the public on matters of public interest. If your company uses a customer-facing chatbot, an AI writing tool, an AI image generator, or emotion/biometric recognition, Article 50 already applies to you, whatever your company size.
This is the obligation most SMEs actually need to act on right now. High-risk obligations (Annex III/Annex I) were pushed back by the 2026 Digital Omnibus; Article 50 was not.
Article 50(1): Chatbot and AI interaction disclosure
If a natural person interacts with an AI system and it isn’t obvious to a reasonably well-informed person that they’re talking to a machine, you have to tell them, unless it’s obvious from the context (e.g. a labelled "AI Assistant" widget) or the system is being used for a lawful purpose like fraud detection or crime prevention. In practice: a support chatbot, a voice assistant, an AI sales agent, all need a clear, unambiguous disclosure at or before the point of interaction.
Article 50(2): Marking synthetic content
Providers of AI systems that generate synthetic audio, image, video, or text content must ensure the outputs are marked in a machine-readable format as artificially generated or manipulated. This is the "watermarking" obligation, and it’s a provider duty (the company that builds/offers the AI system), not primarily a deployer duty. For systems already on the market before 2 August 2026, the deadline for this specific sub-obligation was extended to 2 December 2026 by the Digital Omnibus.
Article 50(3): Deepfake labelling
Deployers of an AI system that generates or manipulates image, audio, or video content constituting a "deepfake" must disclose that the content has been artificially generated or manipulated. This is a deployer duty and sits alongside the provider’s marking obligation under 50(2): the two aren’t interchangeable, and both can apply to the same piece of content.
Article 50(4): AI-generated text on public interest matters
If you deploy an AI system to generate or manipulate text published to inform the public on matters of public interest, you must disclose that the text was artificially generated or manipulated, unless the content has gone through human editorial review and a natural or legal person holds editorial responsibility for it. This exemption is why most professionally edited AI-assisted journalism doesn’t trigger a disclosure requirement, but an unedited auto-published AI news feed likely does.
Practical checklist
Before you can claim Article 50 compliance, you need to be able to answer yes to each of these for every relevant AI system:
- Every AI system in the company is logged somewhere, not just the ones IT approved.
- Each logged system has an Article 50 relevance tag: 50(1), 50(2), 50(3), 50(4), or none.
- Every chatbot or voice AI discloses it’s AI, before or during the interaction, not buried in a footer.
- Every AI-generated image/audio/video output your company produces is marked as synthetic where 50(2) or 50(3) applies.
- Any AI-generated public-interest text is either disclosed as AI-generated or has a named human editor with editorial responsibility.
- You have a timestamped record of when each disclosure was implemented, in case a regulator or a client asks for evidence.
Questions
Does Article 50 apply to internal-only AI tools?
The disclosure duties are triggered by interaction with natural persons or by content that reaches an audience. A purely internal tool with no external-facing output or interaction generally doesn’t trigger 50(1)-(4), but it should still be logged in your AI asset inventory, since that classification can change if its use expands.
Is a small "AI-generated" badge on a chatbot enough?
The Act requires disclosure to be clear to a reasonably well-informed person at the relevant point of interaction. A generic badge buried where users won’t see it before or during the conversation is unlikely to meet that bar. This is an operational judgment call, not a legal one, and if you need certainty, confirm the specific wording and placement with qualified counsel.
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