Executive briefing: EU AI Act
EU AI Act Article 50: The AI Transparency Obligations for Chatbots and AI-Generated Content
Article 50 of the EU AI Act sets AI transparency obligations that have applied since 2 August 2026. People must be told when they are interacting with an AI system, such as a chatbot. AI-generated content must be marked in a machine-readable way. Deployers must disclose deepfakes, emotion recognition and AI-written text published on matters of public interest.
Correct as of 28 September 2026. Regulation and guidance change. If you are reading this later, check for updates before relying on it.
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- Article 50 has applied since 2 August 2026. It was not delayed by the Digital Omnibus.
- Four duties: tell people they are dealing with AI, mark AI-generated content, disclose emotion recognition and biometric categorisation, and label deepfakes and AI-written public-interest text.
- Providers build the disclosure and marking in. Deployers, the companies using the AI, carry the deepfake, public-interest text and emotion recognition duties.
- The only grace period is for machine-readable marking by generative AI systems already on the market before 2 August 2026. It ends on 2 December 2026.
- Disclosure is the minimum. Telling a customer they are talking to AI does not make its answers right.
Why the board should care
Already enforceable
Breaches of Article 50 can be fined up to EUR 15 million or 3% of worldwide annual turnover, whichever is higher (Article 99).
Customer-facing by design
Chatbots, AI voice agents and AI-generated marketing are seen by customers first. A missing disclosure is visible to anyone, including competitors and regulators.
Vendors change tools under you
AI features switched on inside platforms you already use can put AI in front of customers without anyone checking the disclosure.
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FAQ
Frequently asked questions
What is Article 50 of the EU AI Act?
Article 50 sets the Act's transparency obligations. People must be told when they interact with an AI system, AI-generated content must be marked in a machine-readable way, and deployers must disclose deepfakes, emotion recognition, biometric categorisation and AI-written text published on matters of public interest. It has applied since 2 August 2026.
What are the EU AI Act transparency requirements?
Four duties under Article 50: providers must make AI that talks to people disclose itself and must mark AI-generated content; deployers must tell people about emotion recognition or biometric categorisation, and must disclose deepfakes and AI-written public-interest text. Disclosures must be clear, accessible and given at the first interaction at the latest.
Do chatbots have to disclose they are AI under the EU AI Act?
Yes. Under Article 50(1), AI systems that interact directly with people must be designed so the person is told they are dealing with AI, unless that is obvious from the context. The notice must be clear and given at the first interaction at the latest. The same applies to AI voice agents.
Does AI-generated content have to be labelled in the EU?
Providers of generative AI must mark output in a machine-readable, detectable format. Deployers must disclose deepfakes, and AI-generated text published to inform the public on matters of public interest, unless a person has reviewed it and someone holds editorial responsibility. Evidently artistic or satirical work needs only a light-touch disclosure.
When does Article 50 of the EU AI Act apply?
From 2 August 2026. The Digital Omnibus, Regulation (EU) 2026/1744, did not delay it. Generative AI systems already on the market before 2 August 2026 have until 2 December 2026 to meet the machine-readable marking duty only. Telling people they are dealing with AI has no grace period.
Does EU AI Act watermarking apply to AI images and video?
Yes. Article 50(2) requires providers of AI systems that generate synthetic audio, images, video or text to mark the output in a machine-readable format, such as a watermark or metadata, so it can be detected as AI-generated. The European Commission's Code of Practice on AI-generated content sets out recognised ways to do it.
Who has to comply with Article 50: the vendor or the business using the AI?
Both, for different duties. The provider, usually the vendor, builds in the AI disclosure and content marking. The deployer, the business using the AI, must disclose deepfakes, AI-written public-interest text and emotion recognition. A business that builds its own chatbot is its provider.
What is the fine for breaching Article 50?
Up to EUR 15 million or 3% of worldwide annual turnover for the preceding year, whichever is higher. For SMEs, including start-ups, the lower of the two figures applies. National market surveillance authorities enforce Article 50.
Correct as of 28 September 2026. This content reflects the law, official guidance and deadlines as published on that date. The EU AI Act and its guidance, standards and deadlines are still being amended and clarified. If you are reading this after 28 September 2026, check for later amendments, European Commission guidance and harmonised standards before relying on it. It is general information, not legal advice, and AIPEX accepts no liability for decisions taken on it without specific professional advice.
This briefing is general information about Article 50 of the EU AI Act (Regulation (EU) 2024/1689) as amended by Regulation (EU) 2026/1744, and the European Commission's July 2026 guidance, correct at the date last reviewed. Governance guidance, not legal advice. AIPEX is not a certification body. For decisions about specific AI systems, take advice from a qualified lawyer.