Guides · Article 50 · EU AI Act
AI in mobile apps and EU AI Act disclosure
Mobile apps now bundle several AI features at once — a chat assistant, a photo generator, a voice feature, a recommendation feed. Article 50 of the EU AI Act is organised by the kind of AI system rather than by platform, so "is my app covered" is really several questions, one per feature. This guide maps the common feature types to the paragraph each might engage. It is informational only, not legal advice, and does not determine whether the Act applies to your app.
Map each feature, not the app as a whole
The reliable exercise is to list every AI feature the app ships and ask which Article 50 paragraph, if any, its behaviour engages. The same app can touch more than one paragraph, and can be provider-side for some features and deployer-side for others.
- An in-app chat or voice assistant that talks to users → Article 50(1), provider-side disclosure that people are interacting with an AI system, subject to the 'obvious' exception.
- A feature that generates synthetic audio, image, video, or text → Article 50(2), provider-side machine-readable marking of the outputs.
- A feature that infers emotion or categorises people from biometric data → Article 50(3), deployer-side notice plus EU data-protection law.
- A feature that produces deepfake image, audio, or video → Article 50(4), deployer-side disclosure that content is artificially generated or manipulated.
Features that may fall outside the four situations
Not every AI feature lands inside Article 50. A recommendation feed, a ranking algorithm, or on-device personalisation that neither converses with the user as an AI nor generates synthetic content may not engage any of the four paragraphs — though that is a fact-specific reading, and other parts of the EU AI Act (outside Article 50) could still apply. It is more accurate to say such a feature may fall outside Article 50 than to force it into a paragraph it does not fit.
Where and when to surface a disclosure
For features that do engage a paragraph, Article 50(5) asks that the information be clear, distinguishable, given at the latest at the first interaction or exposure, and meet applicable accessibility requirements — which on mobile means legible at the point of use, not buried in a settings screen. Confirm your feature-by-feature mapping with qualified counsel; our free scope check gives an informational read.
Common questions
My app has several AI features — is the whole app in scope?
Article 50 keys on what each AI system does, not on the app as a container. Some features may engage a paragraph while others may fall outside Article 50 entirely. Map each feature to the relevant paragraph and confirm with qualified counsel.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.