EU AI Act Article 50: four transparency duties, tracked per AI system.
Article 50 requires that people are told when they interact with AI, that synthetic content carries machine-readable marking where required, and that specified biometric, deepfake, and public-interest uses carry notices or labels. Govarna turns those duties into a per-system obligation register with owners, disclosure status, and exportable evidence.
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The four Article 50 transparency duties
Article 50 of Regulation (EU) 2024/1689 applies beyond high-risk AI — an ordinary customer-support chatbot may trigger Article 50(1) even when it is not an Annex III high-risk system. Which duties attach depends on your role for each system.
| Duty | Who | Requirement | SaaS example |
|---|---|---|---|
| 50(1) | Provider | Inform people when they interact directly with an AI system, unless this is obvious in context. | Customer-support chatbot or voice assistant |
| 50(2) | Provider | Mark synthetic audio, image, video, or text in a machine-readable and detectable format. | Image, video, voice, or text generation feature |
| 50(3) | Deployer | Inform people exposed to emotion-recognition or biometric-categorisation systems. | A feature inferring emotion from voice, face, or other biometric data |
| 50(4) | Deployer | Disclose deepfakes and certain AI-generated or manipulated public-interest text. | Synthetic video or unreviewed public-interest publication |
For the full duty-by-duty walkthrough — exceptions, adaptable wording, the voluntary Code of Practice, and a 10-step checklist — read the Article 50 deep-dive guide.
Who is covered — and why your role per system matters
A provider develops or offers the AI system under its name; a deployer uses an AI system under its authority in a professional context. A SaaS company can hold different roles for different systems — using a third-party model API does not by itself determine the answer.
If you build or offer systems that interact directly with people (chatbots, voice assistants) or generate synthetic audio, image, video, or text, you must inform people they are interacting with AI unless it is obvious in context, and support machine-readable marking of synthetic outputs. Standard editing assistance that does not substantially alter input data or semantics is excluded.
If you use emotion-recognition or biometric-categorisation systems, you must inform the people exposed to them. If you publish qualifying deepfakes, or AI-generated or manipulated public-interest text without human editorial review, disclosure is required. Artistic, satirical, and fictional works have tailored treatment.
Not sure which role you hold? Take the free deployer assessment — 7 questions, instant suggested classification, no signup needed to see your result.
From the legal text to a per-system obligation register.
Article 50 duties attach system by system. The operational work is knowing which of your AI systems trigger which duty, who owns each disclosure, and what evidence exists that it was implemented.
Every AI system you use or build, in one place — including the chatbots, generation features, and biometric analyses that Article 50 cares about. Manual entry or CSV import.
A suggested EU AI Act role (provider / deployer) and risk tier per system, flagging which systems appear to trigger Article 50(1)–(4). Deterministic, auditable, and reviewable with counsel — not a legal determination.
Each applicable duty becomes a discrete, per-system obligation with an owner, implementation status, and the reasoning for why it applies or does not.
Export the inventory, classifications, disclosure decisions, and change history as a PDF and JSON package whenever a buyer, auditor, or counsel asks.
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Start free trialWhat happens on 2 August 2026?
Article 50 transparency obligations apply from 2 August 2026. A proposed grandfathering rule would give certain existing generative AI systems until 2 December 2026 for specified marking duties, ifthat Omnibus provision is legally adopted — the Commission's Article 50 FAQ confirms the main application date is unchanged. Non-compliance can fall under Article 99(4), with maximum administrative fines of EUR 15 million or 3% of total worldwide annual turnover, subject to the Regulation's rules for undertakings and SMEs. More immediately, visible disclosure failures can create buyer-review and reputational risk.
Regulatory facts reviewed 13 July 2026. Sources: Commission overview and Article 50 FAQ. Informational only, not legal advice; confirm how Article 50 applies to your systems, roles, and deployments with qualified counsel.
Article 50 questions teams ask.
Does Article 50 apply to US companies with no EU office?
It can. Article 2 covers providers placing AI systems on the EU market or putting them into service in the EU, and certain providers or deployers outside the EU where AI-system output is used in the EU. Scope depends on the company role and specific deployment.
Was Article 50 delayed in 2026?
No. The Article 50 transparency duties apply from 2 August 2026. A proposed grandfathering rule would give certain existing generative AI systems until 2 December 2026 for specified marking duties if that Omnibus provision is legally adopted.
Do internal-only AI tools need a disclosure?
Article 50(1) can apply where an AI system interacts directly with employees or other natural persons unless the AI nature is obvious in context. A purely backend system with no direct human interaction is not caught by Article 50(1), though other obligations may apply.
Does Govarna determine whether Article 50 applies to us?
No. Govarna provides suggested, auditable classifications and per-system obligation tracking for you to review with qualified counsel. It is a governance workspace, not a legal determination.
Know which systems trigger Article 50 — and show your work.
Article 50 transparency duties apply from 2 August 2026.
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