EU AI Act · Article 50 transparency obligations
Have you heard of Article 50 of the EU AI Act?
You've probably seen the coverage around the EU AI Act. Almost all of it is about high-risk systems — policing, hiring, credit scoring, border control, critical infrastructure — the kind of AI that decides whether someone gets a job, a loan or a visa. If that is not what your business does, it would be reasonable to conclude the Act is not about you. You might have AI systems in your business, but they're not part of the high-risk conversation happening in the coverage.
Unfortunately, if you use any AI in your business, especially if that AI has any interaction with a human — and any of those humans are in Europe — then the Article applies to your business. Article 50 is a separate part of the law and it focuses on something much smaller: whether people can tell they are dealing with an AI. A support chatbot is not high-risk, but it still falls under Article 50.
What is Article 50? read the Article →
Article 50 of the EU AI Act is the transparency part of the law. It does not ask whether your AI is safe, accurate or well built. It asks one thing: are the people on the other side of it being told what they are dealing with. It sets four duties, and which of them reach you depends on what your AI actually does.
- People must be told they are interacting with an AI, not a person. Article 50(1) — binding since 2nd August 2026, no grace period.
- AI-generated content must carry a machine-readable mark. Article 50(2) — binding since 2nd August 2026, or from 2nd December 2026 for systems already on the market before that date.
- Emotion recognition and biometric categorisation must be disclosed to the people subject to them. Article 50(3) — binding since 2nd August 2026, no grace period.
- Deepfakes, and AI-generated text published on matters of public interest, must be labelled. Article 50(4) — binding since 2nd August 2026, no grace period.
It reaches beyond Europe. A business outside the EU is in scope if its AI system is used by people inside it, which is why a great many businesses who have never thought of themselves as subject to European law are. Content generated and published before 2nd August 2026 does not need labelling retrospectively.
Breaches of Article 50 carry fines of up to €15 million or 3% of worldwide annual turnover. For small and medium businesses, including start-ups, Article 99(6) reverses that: the ceiling is whichever of the two is lower, not higher — so for a business turning over €2 million it is 3%, or €60,000, rather than €15 million.
Would you like a free check of your website to see if the EU AI Act affects you?
Please input your website address into the box below. We read your own published pages and can tell you whether the Act appears to reach you. No sign-up, no email, nothing sent to you.
What a full assessment adds
The check above reads what your website says about itself. That is genuinely useful, but it is also genuinely limited because it can only see what is published. An Article 50 Assessment covers the rest:
An Article 50 Assessment:
- Every AI touchpoint, including the ones not visible on a public page — internal tools, email assistants, features bought in from a vendor.
- Which obligation attaches to each, and which attach to none.
- What is currently unmarked or undisclosed, and what to do about it.
- A written record that the assessment was carried out.
- Every action in one list, so the whole job is visible in one place — and again under the obligation it belongs to, so nothing is orphaned.
- What each conclusion rests on, stated under it, so any finding can be traced back to the answer or the page that produced it.
- Which of the two dates applies to you where content marking is concerned — the answer differs depending on when your system went live, and it is settled rather than left open.
- Anything that could not be assessed, named as unassessed rather than quietly passed over. An unknown is reported as an unknown.
- What the assessment does not cover, stated plainly — including the parts of the AI Act that are separate from Article 50.
It starts with a questionnaire that takes about fifteen minutes, because we read your site first and ask about what is actually there. Not “do you use AI in customer service?” — but “your site runs Intercom; is it answered by people, by set rules, or by Intercom’s AI?” Every question says why it is being asked.
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