Guides · Article 50 · EU AI Act
AI search results and EU AI Act disclosure
"AI search" covers two quite different behaviours: ranking and retrieving existing results, and generating a written answer or summary on top of them. Under Article 50 of the EU AI Act these can land differently, so it helps to separate them. This guide explains how. It is informational only, not legal advice, and does not determine whether the Act applies to your search feature.
Pure ranking may fall outside the four situations
A search feature that orders existing documents or products — without conversing with the user as an AI and without generating synthetic content — may not fit any of Article 50's four situations. That is a fact-specific reading, and other parts of the EU AI Act (outside Article 50) could still apply, but on that narrow description the transparency paragraphs may not be engaged. It is more honest to say such a feature may fall outside Article 50 than to force it into a paragraph.
Generative answers may point to Article 50(2)
Modern search often adds an AI-written summary or direct answer above the links. That generated text is a different matter: Article 50(2) addresses providers of AI systems generating synthetic text (among other content types), requiring outputs be marked in a machine-readable format and detectable as artificially generated or manipulated, subject to its carve-outs (Regulation (EU) 2024/1689). Whether a generative answer feature falls inside the paragraph — and whether the assistive-editing or no-substantial-alteration carve-out applies — is fact-specific. The duty, if it applies, is provider-side.
Separate the behaviours, then map each
The practical step is to split your search product into its ranking component and any generative component, and assess each against Article 50 on its own terms. Where a generative answer appears, treat it like other synthetic-text output; where only ranking occurs, document why it may sit outside the transparency paragraphs. Confirm with qualified counsel — our free scope check helps frame the mapping but does not decide scope.
Common questions
Does an AI answer box on a search page need marking?
An AI-generated answer is synthetic text, so Article 50(2)'s provider-side marking may be worth examining, subject to its carve-outs. Pure ranking of existing results may fall outside Article 50, though other parts of the Act could apply. Both are fact-specific — 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.