Article 50 Transparency Requirements (Chatbots, Synthetic Media, Deepfakes)
Article 50 transparency requirements are the EU AI Act's disclosure rules: people must be told when they are talking to a machine, AI-generated content must carry machine-readable marking, and deepfakes must be labelled. They apply to plenty of systems that are nowhere near high-risk, which is why a normal SaaS chatbot still has homework. Here is the who-must-say-what matrix.
The disclosure matrix
| You run... | Article 50 asks for... |
|---|---|
| A chatbot or any AI that interacts with people | Tell users they are interacting with AI, unless it is obvious from context |
| A generator of synthetic audio, image, video, or text | Mark outputs as artificially generated, in a machine-readable way |
| An emotion-recognition or biometric-categorisation system | Inform the people exposed to it |
| A deepfake generator or publisher | Disclose that the content was artificially generated or manipulated |
The duties stack. A support bot that also drafts marketing images owes both the interaction notice and the content marking.
Example wording you can adapt
For a chatbot, a single line at the start of the conversation does the structural work: "You're chatting with an AI assistant. A human can take over on request." For generated media, the disclosure lives in two layers, a visible label where context demands one and metadata marking in the file itself. We generate tailored notice text as one of the document types in AI Comply HQ, matched to your system's modality and audience.
When does Article 50 apply?
From 2 August 2026 under the current text of the Regulation, alongside most of the Act's remaining obligations. Building the disclosures now costs little. Retrofitting marking into a content pipeline in July 2026 costs a lot.
How does this interact with high-risk duties?
Article 50 sits on top. A high-risk hiring system that chats with candidates owes the interaction disclosure and the full high-risk set from the provider checklist. Classification first, then disclosures: run the free risk check if you have not.
FAQ
Our chatbot is obviously a bot. Do we still need the notice?
Article 50 excuses disclosure when it is obvious to a reasonably well-informed person. "Obvious" is doing heavy lifting there, and the notice costs one sentence. We ship it.
Does our own product disclose?
Yes. Blake, the assistant inside AI Comply HQ, introduces itself as AI. We follow the same rule we generate documents for.
Generate your transparency notice
Sources
This page is informational content, not legal advice. Talk to a qualified lawyer about your specific situation.