FAQEU AI Act

EU AI Act Article 50 Transparency Disclosures

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

Use this FAQ to 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
May 9, 2026
Questions
5

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Article 50 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.

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5 of 5 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.
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.

Article 50 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 Article 50 limits it to uses authorised by law for detecting, preventing, investigating, or prosecuting criminal offences.
Question 3

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.
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 deep fake 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, Article 50 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.
Question 5

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 Article 50 text and the actual user or publication experience.

  • Map the relevant Article 50 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.
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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.

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Primary sources

References and citations

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"
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"
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