Transparency notices under Article 50 must be provided in a clear and distinguishable manner, in a form that the people they are meant to inform can actually perceive and understand, taking into account accessibility needs, language, timing and the channel used. A notice that is present in code or in a document but cannot be perceived by a person using assistive technology, or cannot be understood in the language and context of exposure, does not inform the person it is meant to reach.
What does clear and distinguishable mean for accessibility?
Clear and distinguishable means that the notice is perceptible, understandable, and not confused with other content, for the people it is meant to inform. Perceptible means it can be seen, heard, or otherwise perceived through the channel and technology the person uses, including screen readers, voice interfaces, and other assistive technology. Understandable means the wording is plain, direct, and free from jargon that the audience will not know. Distinguishable means the notice stands out from surrounding content, is not buried in a footer or a long document, and is not presented in a way that makes it look like advertising or a general credit. A notice that meets the visual design standard but is invisible to a screen reader, or that is readable by a screen reader but uses language the audience cannot follow, has met only part of the standard.
How should notices work with assistive technology?
Notices should be implemented in a way that assistive technology can expose them at the right time and in the right order. For a web or application interface, that means using semantic markup, labels, and live regions where appropriate, so that a screen reader announces the disclosure when the interaction begins. For voice interfaces, it means speaking the disclosure clearly at the start of the interaction, at a pace and volume the listener can follow. For physical signage, it means considering tactile, audible, and visual alternatives where the exposure context requires them. The provider or deployer should test the notice with assistive technology users, record the test, and fix any case where the notice is skipped, announced too late, or announced in a form that does not convey its meaning. Accessibility testing should be part of disclosure testing, not a separate exercise carried out after launch.
For the broader regulatory framework, see Transparency duties for AI.
What language and wording should be used?
Notices should be given in the language or languages the affected people use in the context of exposure, in plain wording that states the fact directly. For interaction disclosure, the wording should state that the person is interacting with an AI system. For synthetic content, it should state that the content was artificially generated or manipulated. For emotion recognition or biometric categorisation, it should state that the system is in operation and what it does. Wording should avoid euphemism, such as describing an AI system as a digital assistant without stating that it is AI, where that wording could mislead. Translations should be checked by a competent speaker for accuracy and plainness, and should be version-matched to the original, so that a person reading a translation receives the same information as a person reading the original.
How do timing and placement affect accessibility?
Timing and placement determine whether a notice is accessible in practice. A notice given after a long interaction, after content has been viewed, or in a place the person has already passed, is less accessible than a notice given at the first interaction, at the point of exposure, or attached to the content itself. Placement should follow the person's journey: at the entrance to a space where a system operates, at the start of a conversation, or on the content where it is viewed. Where an interaction continues over time, a reminder may be needed, particularly where the person may have forgotten the initial disclosure or where a new person joins the interaction. The timing and placement for each channel should be recorded in the transparency file, with the reasoning, so that a reviewer can see why the notice appears where and when it does.
How should notices be designed for different channels?
Different channels need different notice designs. A chat interface needs an in-flow disclosure that is announced by assistive technology. A voice interface needs a spoken disclosure. A video needs a visible and, where appropriate, audible disclosure that remains present long enough to be perceived. A physical space needs signage at the point of exposure, with alternatives for people who cannot read the sign. A published article needs a disclosure attached to the text, not only in a separate policy page. The design for each channel should be tested with users of that channel, including assistive technology users, and the test should be recorded. A single notice design copied across channels, without considering how each channel is perceived, is unlikely to be accessible in every channel.
Continue with Testing disclosures with users.
What does this guide not decide?
This guide does not decide whether a particular notice is accessible, clear, or distinguishable, or whether a translation or an assistive technology implementation is sufficient. It does not assess a design, a sign, or a script. Those questions depend on the notice, the channel, the audience, and the accessibility requirements that apply, together with the consolidated legal text. A provider or deployer should test its notices with representative users including assistive technology users, record the test and the fixes, and confirm the position with a competent authority or legal adviser where the audience includes people at particular risk of missing the notice.
Frequently asked questions
Must a notice work with a screen reader?
Yes, in practical terms. A notice that cannot be perceived by a person using assistive technology does not inform that person. Notices should be implemented with semantic markup, labels and timing that assistive technology can expose, and should be tested with assistive technology users.
Is plain language required?
Article 50 requires information in a clear and distinguishable manner. Plain, direct wording that states the fact, in the language the audience uses, is the practical way to meet that standard. Jargon, euphemism and buried wording should be avoided and tested with representative users.
Does one notice design work for every channel?
No. Chat, voice, video, physical space and published text each need a design suited to how the notice is perceived in that channel. Test each channel separately, including with assistive technology users, and record the design and test for each.
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This article is an informational overview, not a legal determination. Check the current legal text and official implementation guidance for your system and role.
Consolidated Regulation (EU) 2024/1689 ↗AI Act Service Desk Article 50 ↗European Commission AI Act overview ↗