Article 50 of the EU AI Act defines transparency obligations for AI systems that interact with humans or generate content. From August 2, 2026, these obligations are binding for all EU companies regardless of size. This article breaks down each paragraph and provides an actionable checklist.
The Four Paragraphs of Article 50
Paragraph 1: AI Interaction Disclosure
Affects: AI chatbots, phone assistants, automated advisory systems. Obligation: Users must be clearly informed at the start of interaction that they are communicating with an AI system. Implementation: Adjust greeting text or add visual indicators.
Paragraph 2: Machine-Readable Labeling of Synthetic Content
Affects: AI systems generating text, images, audio, or video. Obligation: Outputs must be labeled as AI-generated in machine-readable format. For text, this means metadata; for images, watermarks or C2PA-standard metadata.
Paragraph 3: Emotion Recognition and Biometric Categorization
Affects: Emotion recognition or biometric categorization systems. Obligation: Affected persons must be informed. Not relevant for most SMEs.
Paragraph 4: Deepfake and Text Manipulation Disclosure
Affects: AI-generated or manipulated content published to inform the public about matters of public interest. Obligation: AI generation must be disclosed.
Practical Checklist for SMEs
Chatbots and phone assistants: Does interaction begin with AI disclosure? Is disclosure clear and comprehensible? Is it shown before the actual conversation starts?
Published AI content: Is there an internal process for identifying AI-generated content? Are published AI texts, images, and videos labeled? Is labeling machine-readable?
Internal AI use: Does an AI inventory exist? Do employees know which tools fall under the obligations? Are there internal guidelines for handling AI-generated content?
Documentation: Are all measures documented? Is there a responsible person for ongoing compliance?
FAQ
Must I label every AI-generated blog article? If the article was generated by an AI system and published: yes, labeling should be machine-readable. For AI-assisted editing (e.g., AI proofreading), the situation is less clear — transparent handling is recommended.
Does Article 50 apply to emails written with AI? Internal communication does not fall under Article 50. For customer-facing communication by automated AI systems, interaction disclosure may apply.
What happens if I miss the deadline? Fines for transparency violations can reach €15 million or 3% of annual turnover. For SMEs, the lower amount always applies.
