EU AI Act Article 50 checklist

The 5-step Article 50 checklist

Article 50 of the EU AI Act covers transparency obligations for certain AI systems and AI-generated content. These rules come into effect in August 2026. Here's a checklist to get ready.

Step 1: Identify where users interact with AI

Map every touchpoint where a user might interact with an AI system: chatbots, voice assistants, AI email assistants, AI agents. Include customer-facing and internal-facing systems.

Step 2: Decide where disclosures should appear

For each interaction point, decide where the disclosure goes: first message in a chat, spoken opener for voice, signature for email, profile bio for messaging apps.

Step 3: Prepare clear wording for each channel

Write disclosure texts that are clear, concise, and appropriate for the medium. Use the free chatbot disclosure text generator to get started.

Step 4: Decide when AI-generated content needs a label

Audit what AI-generated content you publish (text, images, audio, video). Determine which medium-specific rules apply. Apply appropriate labels at the point of publication.

Step 5: Keep a record of your disclosure and labeling decisions

Track each asset: date, medium, legal branch assessed, label applied and reviewer. This creates a useful decision record if the process is later reviewed.

What needs to be labeled

• AI-generated text published on matters of public interest (unless human editorial review applies)
• AI-generated images, audio, and video — providers must mark outputs as machine-readable and detectable
• Deepfakes — deployers must disclose that content is artificially generated or manipulated
• Emotion recognition and biometric categorization — deployers must inform persons exposed

Branch-specific limits and exceptions

• Personal, non-professional activity can fall outside the Act's scope
• The "obvious interaction" exception belongs to Article 50(1) AI interactions; it is not a general content-disclosure waiver
• The public-interest text duty has an exception where a human exercises editorial control and a person holds editorial responsibility

Free tool

Generate disclosure texts for your specific channel and industry using the free chatbot disclosure text generator. No sign-up required.