EU AI Act — Article 50 transparency obligations
European Union · Regulation (EU) 2024/1689, Art. 50 · effective 2026-08-02 · Art. 50(2) machine-readable marking for systems already on the market may be deferred to Dec 2, 2026 under the AI Omnibus; Commission guidelines published May 2026.
Summary
Any AI system that interacts directly with people (chatbots, virtual assistants, AI phone systems) must inform them they are dealing with AI unless it is obvious. Deployers must label deepfakes and disclose AI-generated text published to inform the public, and must tell people when emotion-recognition or biometric-categorisation systems are used. Applies to businesses anywhere whose systems reach EU users.
Who must comply
Providers and deployers of AI systems used by people in the EU, regardless of where the business is located.
What you must disclose
Clear and distinguishable notice, at the latest at first interaction, that the person is interacting with an AI system; visible labels on deepfakes; disclosure of AI-generated public-interest text.
When: Before or at the first interaction or exposure; not buried in footers or terms.
Other duties
- Do not strip machine-readable AI markers from generated content.
- Accessible presentation of notices.
Exemptions
- Where AI use is obvious to a reasonably well-informed person.
- Assistive edits that don't substantially alter content.
- Certain law-enforcement uses.
Penalties
Up to €15 million or 3% of worldwide annual turnover, whichever is higher (the lower amount for SMEs and start-ups).
Enforced by: National market-surveillance authorities of each EU member state.
Triggered by
Sources
- Article 50 (EU AI Act Service Desk)
- European Commission FAQ — Transparency obligations under Article 50
- Greenberg Traurig — Commission details transparency obligations under the AI Act (June 2026)
Last reviewed 2026-09-09. Not legal advice.
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