Guides · Article 50 · EU AI Act
AI personalization and EU AI Act Article 50
AI personalisation tailors what a user sees — the homepage, the offers, the ordering — based on their behaviour. Because it is so widespread, teams ask whether Article 50 of the EU AI Act requires a disclosure. A system that only reorders or selects existing content may fall outside Article 50's four situations, though that is fact-specific and other parts of the Act could still apply. This guide explains why. It is informational only, not legal advice.
Personalisation against the four paragraphs
Article 50 attaches its transparency duties to four situations: direct interaction with people (50(1), providers), generation of synthetic content (50(2), providers), emotion recognition or biometric categorisation (50(3), deployers), and deepfakes or certain public-interest text (50(4), deployers). Personalisation that selects, ranks, or reorders existing content typically fits none of these — it neither converses with the user as an AI nor generates synthetic outputs. On that description it may fall outside Article 50's transparency paragraphs.
Two edges that can change the answer
First, if personalisation is driven by categorising people from biometric data, Article 50(3)'s deployer-side notice duty could come into view — whether a given personalisation engine does that is a fact-specific question about its inputs. Second, if the personalised experience also generates content (a tailored AI-written message, for instance) or converses with the user, those elements could independently engage 50(2) or 50(1). Beyond Article 50, other parts of the EU AI Act may still apply. The honest framing is that personalisation may fall outside Article 50's transparency obligations, not that the Act is irrelevant.
Documenting rather than assuming
Set out what your personalisation system uses as inputs and what it produces for the user. Map each element to the four situations, and where nothing fits, record the reasoning. Where a biometric, generative, or conversational element appears, assess it on its own terms. Confirm with qualified counsel; our free scope check frames the mapping without deciding scope.
Common questions
Does a personalised homepage need an AI disclosure?
Personalisation that only selects or reorders existing content may fall outside Article 50's four situations, though that is fact-specific and other parts of the Act could apply. Biometric categorisation or generated content could change the analysis. 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.