Guides · Article 50 · EU AI Act
AI search and answer engines under Article 50
AI answer engines and generative search return written answers rather than a list of links, often in a conversational interface. Two Article 50 paragraphs can bear on that: 50(1), the provider-side duty to inform people they are interacting with an AI system, and 50(2), the provider-side marking of synthetic text. This guide explains both, and the relevant carve-outs, from the regulation text. It is informational only, not legal advice, and does not name any tool category as in or out of scope.
Conversational answers — Article 50(1)
Where an answer engine is intended to interact directly with people through a chat-style interface, Article 50(1) can come into view. That paragraph is written on the provider of the system: they must ensure it is designed so people are informed they are interacting with an AI system, unless this is obvious to a reasonably well-informed, observant and circumspect person given the context. A tool branded plainly as an AI answer engine may make the AI nature more obvious than one that mimics a human respondent. Whether the interface clears that bar is fact-specific.
Generated answer text — Article 50(2) and its carve-outs
The written answer itself raises Article 50(2), the provider-side marking of synthetic text as detectable and artificially generated. The paragraph carves out systems to the extent they perform an assistive function for standard editing or do not substantially alter the input data or the semantics thereof — language that can be argued over where an engine mainly retrieves and quotes existing sources versus where it composes an original synthesis. Whether generated answers fall inside 50(2), and whether a carve-out applies, are fact-specific questions. Separately, if an engine publishes AI-generated text to inform the public on matters of public interest, the text limb of Article 50(4) can raise a deployer-side question, subject to its human-review and editorial-responsibility carve-out.
Common questions
Does an AI answer engine need to disclose that answers are AI-generated?
Article 50(1) can point the provider toward informing people they are interacting with an AI system, and 50(2) toward marking synthetic text, subject to carve-outs. Whether either applies to a given engine — and whether the 50(4) text limb is in play — is fact-specific. Verify with qualified counsel.
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Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.