FAQEU AI Act

EU AI Act Article 50 Transparency Disclosures

Q: When must Article 50 information be shown to natural persons?

For Article 50(1) to (4), the information must be clear and distinguishable and provided at the latest at the time of the first interaction or exposure. It must also conform to applicable accessibility requirements.

Q: Does Article 50 require visible labels on every AI-generated output?

Article 50(2) imposes a provider duty to make synthetic outputs machine-readable and detectable as artificially generated or manipulated. Visible disclosure duties for deepfakes and certain public-interest text sit mainly on deployers under Article 50(4).

Q: What notices do deployers need for emotion recognition and biometric categorisation?

Deployers of an emotion recognition system or a biometric categorisation system must inform the natural persons exposed to the operation of the system. Article 50 also states that personal data must be processed in accordance with the applicable EU data-protection instruments, including the GDPR, Regulation (EU) 2018/1725, or Directive (EU) 2016/680 depending on the context. Identify where people are exposed to the system: app flow, physical premises, camera zone, call center, interview, testing setting, or public service counter. Make the notice visible before or at first exposure and align it with accessibility requirements for the channel. Keep the biometric or emotion-recognition purpose, data-protection role, notice text, placement evidence, and any legal basis analysis together. Use the Article 50 law-enforcement exception only where the system is permitted by law to detect, prevent, or investigate criminal offences, subject to safeguards and Union law.

Q: When can AI-generated public-interest text avoid an Article 50 disclosure?

Article 50(4) supports two exceptions: use authorised by law to detect, prevent, investigate, or prosecute criminal offences, or AI-generated content that has undergone human review or editorial control where a natural or legal person holds editorial responsibility for publication.

Q: Does Article 50 remove other EU AI Act or national transparency obligations?

No. Article 50 says its transparency duties do not affect Chapter III requirements and are without prejudice to other transparency obligations under Union or national law for deployers of AI systems.

Q: Are the Commission Article 50 transparency guidelines final?

Yes. The Commission published final Article 50 transparency guidelines on 20 July 2026. They state the Commission's implementation view but do not amend the Regulation or bind the Court of Justice.

Article 50 requires targeted transparency notices and markings for certain AI interactions and AI-generated or manipulated content.

This FAQ helps separate provider duties from deployer duties, place notices at the right moment, and document only the exceptions supported by the AI Act text.

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Author

Sorena AI

Published

May 9, 2026

Updated

Jul 25, 2026

Questions

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated Jul 25, 2026

Overview

of Regulation (EU) 2024/1689 applies from 2 August 2026 as part of Chapter IV. It covers transparency obligations for providers and deployers of certain AI systems, including direct AI interactions, machine-readable marking of synthetic outputs, notices for emotion recognition and biometric categorisation, deepfake disclosures, and AI-generated public-interest text. The underlying duties are binding. The Commission published final Article 50 guidelines on 20 July 2026. The separate Code of Practice on marking and labelling AI-generated content remains a voluntary compliance tool; the Commission published its adequacy opinion on 9 July 2026. Regulation (EU) 2026/1744, published on 24 July 2026 and entering into force on 27 July 2026, gives providers of synthetic-content systems placed on the market before 2 August 2026 until 2 December 2026 to take the steps needed to comply with Article 50(2).

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6 of 6 questions

Question 1

What does Article 50 require for direct interactions with AI systems?

Providers must design and develop AI systems intended to interact directly with natural persons so that the people concerned are informed that they are interacting with an AI system.

The notice is not required when the interaction is obvious to a reasonably well-informed, observant, and circumspect person in the circumstances and context of use. The direct-interaction duty also has a law-enforcement exception for systems authorised by law to detect, prevent, investigate, or prosecute criminal offences, subject to safeguards, unless the system is available for the public to report a criminal offence.

Place the notice in the product experience before or during the first AI interaction, not only in back-office documentation.
Test whether a normal user can tell they are interacting with an AI system in the actual context, language, device, and channel.
Keep a short record of the notice text, placement, version, language coverage, and the reason any obviousness or law-enforcement exception was used.

Do EU AI Act disclosures apply to chatbots and AI assistants?

Yes, where the AI system is intended to interact directly with natural persons. The provider must design and develop the system so the person is informed that they are interacting with an AI system, unless that fact is obvious in the context of use.

When must information be shown to natural persons?

For (1) to (4), the information must be clear and distinguishable and provided at the latest at the time of the first interaction or exposure. It must also conform to applicable accessibility requirements.

Do synthetic-content systems already on the EU market have the same (2) deadline?

Regulation (EU) 2026/1744 creates a limited transition for the provider marking duty: providers of AI systems, including general-purpose AI systems, that generate synthetic audio, image, video, or text and were placed on the market before 2 August 2026 must take the necessary compliance steps by 2 December 2026. The amendment does not postpone the other duties, which apply from 2 August 2026.

Question 2

What must providers do for synthetic audio, image, video, or text outputs?

Providers of AI systems, including general-purpose AI systems, that generate synthetic audio, image, video, or text content must ensure the outputs are marked in a machine-readable format and detectable as artificially generated or manipulated.

frames this as a technical design duty: the marking solution must be effective, interoperable, robust, and reliable as far as technically feasible, taking account of content type, implementation cost, and the generally acknowledged state of the art.

Record which output types the system can generate or manipulate: audio, image, video, text, or a combination.
Document the marking or detection mechanism, where it is applied in the generation pipeline, and how it behaves across export, editing, compression, and publication channels.
Do not treat standard editing assistance as automatically in scope when it does not substantially alter the deployer's input data or its semantics; keep the product facts that support that conclusion.
Escalate any law-enforcement exception to legal review because limits it to uses authorised by law for detecting, preventing, investigating, or prosecuting criminal offences.

Does require visible labels on every AI-generated output?

(2) imposes a provider duty to make synthetic outputs machine-readable and detectable as artificially generated or manipulated. Visible disclosure duties for deepfakes and certain public-interest text sit mainly on deployers under Article 50(4).

Question 3

What notices do deployers need for emotion recognition and biometric categorisation?

Deployers of an or a must inform the natural persons exposed to the operation of the system.

also states that personal data must be processed in accordance with the applicable EU data-protection instruments, including the GDPR, Regulation (EU) 2018/1725, or Directive (EU) 2016/680 depending on the context.

Identify where people are exposed to the system: app flow, physical premises, camera zone, call center, interview, testing setting, or public service counter.
Make the notice visible before or at first exposure and align it with accessibility requirements for the channel.
Keep the biometric or emotion-recognition purpose, data-protection role, notice text, placement evidence, and any legal basis analysis together.
Use the law-enforcement exception only where the system is permitted by law to detect, prevent, or investigate criminal offences, subject to safeguards and Union law.

Question 4

How should deployers disclose deepfakes and AI-generated public-interest text?

Deployers that use an AI system to generate or manipulate image, audio, or video content constituting a must disclose that the content has been artificially generated or manipulated.

Deployers that publish AI-generated or manipulated text for the purpose of informing the public on matters of public interest must also disclose that the text has been artificially generated or manipulated, unless the supported human-review and editorial-responsibility exception applies.

For image, audio, or video, assess whether the content resembles existing persons, objects, places, entities, or events and would falsely appear authentic or truthful.
For artistic, creative, satirical, fictional, or analogous works, limits the disclosure to the existence of generated or manipulated content in an appropriate manner that does not hamper display or enjoyment.
For public-interest text, document whether the publication underwent human review or editorial control and whether a natural or legal person holds editorial responsibility.
Keep disclosure copy, publication URL or placement, content type, review owner, and exception rationale with the release record.

When can AI-generated public-interest text avoid an disclosure?

(4) supports two exceptions: use authorised by law to detect, prevent, investigate, or prosecute criminal offences, or AI-generated content that has undergone human review or editorial control where a natural or legal person holds editorial responsibility for publication.

Does remove other EU AI Act or national transparency obligations?

No. says its transparency duties do not affect Chapter III requirements and are without prejudice to other transparency obligations under Union or national law for deployers of AI systems.

Question 5

How do the final transparency guidelines and code affect Article 50 work?

The Commission published final guidelines on transparency obligations on 20 July 2026. The guidelines explain the Commission's interpretation of scope, definitions, exceptions, timing, and the relationship between the provider and deployer duties. They support implementation but do not replace the Regulation or an authoritative interpretation by the Court of Justice.

The Code of Practice on marking and labelling AI-generated content was published on 10 June 2026. It is voluntary and is intended to help signatories demonstrate compliance with the duties covered by the code. The Commission published its assessment of the code on 9 July 2026. Keep the binding Article 50 analysis, the final guidelines, and any code commitments as separate evidence.

Binding rule: map the product activity to the applicable paragraph of and the 2 August 2026 application date.
Voluntary code: record whether the organisation signs, which commitments it follows, and what evidence demonstrates those commitments.
Final guidance: record the 20 July 2026 version and use it as Commission interpretation, not as an amendment to .
Change control: assign an owner to track later corrections, translations, court judgments, or amendments that alter the implementation basis.

Is the June 2026 Code of Practice legally mandatory?

No. The code is voluntary. It may provide a structured way for signatories to demonstrate compliance with the duties it covers, but the binding duties come from and apply whether or not a provider or deployer signs the code.

Are the Commission transparency guidelines final?

Yes. The Commission published final transparency guidelines on 20 July 2026. They state the Commission's implementation view but do not amend the Regulation or bind the Court of Justice.

Question 6

What evidence should teams keep for Article 50 transparency disclosures?

A useful evidence file separates provider technical marking duties from deployer disclosure duties. It should show the triggering capability, affected natural persons, notice or marking mechanism, timing, accessibility handling, and any exception relied on.

The evidence should be product-specific enough for a reviewer to reproduce the conclusion from the text and the actual user or publication experience.

Map the relevant paragraph to the system activity it affects, then note the concrete check or record needed for direct interaction, synthetic output marking, emotion recognition, biometric categorisation, deepfake disclosure, or public-interest text.
Provider or deployer owner, with supplier inputs if the product uses a third-party model or hosted AI system.
Notice text, label text, or machine-readable marking description, including language and accessibility coverage.
Screenshots, rendered pages, exported files, logs, or test results showing first interaction, first exposure, or published disclosure placement.
Exception record for obvious interactions, standard editing assistance, law-enforcement authorisation, artistic or satirical works, or human review with editorial responsibility.

Recommended next step

Review EU AI Act transparency disclosures against the product experience

Sorena can help turn Article 50 duties into product-specific notice text, marking checks, accessibility evidence, and release-review records.

Research workflow

Open Research Copilot for EU AI Act

Ask questions tied to cited sources about Article 50 notices, synthetic content marking, deepfake disclosures, public-interest text, timing, and exceptions.

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Talk to Sorena

Talk through Article 50 readiness

Review your AI interaction notices, generated-content markings, biometric or emotion notices, and publication disclosures with Sorena.

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Primary sources

References and citations

European Commission - Code of Practice on marking and labelling of AI-generated content

digital-strategy.ec.europa.eu

Referenced sections

Commission and AI Office page recording the final code's 10 June 2026 publication, its voluntary status, the Article 50(2) and Article 50(4) workstreams, and the adequacy assessment status captured in July 2026.

"marking and labelling of AI-generated content"

European Commission - European Artificial Intelligence Act comes into force

ec.europa.eu

Referenced sections

Commission press release summarising Article 50-style specific transparency risks, including chatbot disclosures, deepfake labelling, biometric categorisation notices, emotion recognition notices, and machine-readable synthetic content marking.

"Specific transparency risk"

European Commission - Guidelines on Article 50 transparency obligations

digital-strategy.ec.europa.eu

Referenced sections

Final Commission guidelines published on 20 July 2026 for Article 50 scope, definitions, provider and deployer duties, exceptions, timing, accessibility, and related horizontal issues.

"Guidelines on transparency obligations"

Regulation (EU) 2024/1689 (Artificial Intelligence Act)

eur-lex.europa.eu

Referenced sections

Primary legal text for Article 50 provider and deployer transparency duties, timing, accessibility, exceptions, and the 2 August 2026 application date for Chapter IV.

"Transparency obligations for providers and deployers"

Regulation (EU) 2026/1744 (Digital Omnibus on AI)

eur-lex.europa.eu

Referenced sections

Binding amendment published on 24 July 2026, entering into force on 27 July 2026, which revises Article 50(7) and gives providers of synthetic-content systems placed on the market before 2 August 2026 until 2 December 2026 to take the steps needed to comply with Article 50(2).