A careful introduction to selected disclosure and marking duties under Article 50.
Identify the interaction
Record whether users directly interact with an AI system and whether they would otherwise understand that they are interacting with AI. Review exceptions in the legal text.
Generated or manipulated content
Specific marking and disclosure duties can apply to generated content, deepfakes and certain text on matters of public interest. Article 50 sets distinct duties for providers and deployers.
Read Article 50 in the regulation ↗Application date
The transparency rules began applying on 2 August 2026. The official timeline also identifies a later transition for certain systems already placed on the market.
Separate provider and deployer duties
Article 50 places different duties on those supplying certain AI systems and those using their outputs. For direct human interaction, the provider must design the system so people are informed they are interacting with AI, subject to the article’s conditions. Providers of systems generating synthetic audio, image, video or text content face a marking and detection requirement. A deployer’s disclosure duties arise in specified uses such as emotion recognition, biometric categorisation, deepfakes and certain public-interest text.
Read Article 50 ↗What should a disclosure explain?
The form should be clear and distinguishable, provided at the appropriate time, and accessible in the circumstances. The legal rule differs by use, so a generic footer saying “AI may be used” is not a reliable substitute for reviewing the particular obligation. Teams should decide who delivers the notice, where it appears, how it works for assistive technologies and how they will test it with users.
Map your deployer role ↗Examples and limits
A service chatbot may trigger the interaction notice unless the AI nature is obvious to a reasonably well-informed person in context. A manipulated video may call for a deepfake disclosure by its deployer, with particular treatment for artistic and similar works. An editing aid that does not substantially alter input may be treated differently under the provider marking rule. The specific exceptions and circumstances require Article 50 review.
Compare the classification categories ↗Operationalise the duty
Inventory output types, delivery channels and audiences. Give the product and publishing teams a decision record for whether a notice or machine-readable marking is needed and how it is implemented. Check the transition for certain systems already on the market before 2 August 2026 against the current official timeline; do not apply one date to every Article 50 obligation.
Check the staged dates ↗This guide is an orientation, not a legal determination. Check the current legal text and official implementation guidance for your system.
Read the AI Act ↗European Commission overview ↗