Guides · Article 50 · EU AI Act
Building an AI systems inventory
Before you can decide which Article 50 transparency duties touch your organisation, you need to know what AI you actually run. An AI systems inventory is the practical first artifact most teams build. This guide explains what to capture and why, mapped to the four paragraphs of Article 50. It is informational only, not legal advice, and an inventory does not by itself establish that any obligation is met.
Why the inventory comes first
Article 50 assigns its duties by the kind of AI system and by whether you are a provider or a deployer. You cannot map obligations you have not listed. An inventory turns a vague 'do we need AI disclosures?' into a concrete, per-system question, and gives counsel something specific to review rather than a general worry.
What to record per system
- A name and short description of each AI system or AI feature, and where it runs (which product, page, or flow).
- The output types it can produce — audio, image, video, text — since 50(2) marking turns on that.
- Whether you are provider-side (you built or place the system on the market) or deployer-side (you use it), or both, for that system.
- Which Article 50 paragraph it might engage: 50(1) direct interaction, 50(2) synthetic content, 50(3) emotion recognition or biometric categorisation, 50(4) deepfakes or public-interest text.
- The disclosure or marking approach in place, and where in the product it surfaces.
- Any carve-out you may rely on, noted for counsel rather than treated as settled.
Keeping it useful over time
An inventory drifts as features ship. Teams commonly assign an owner, review it on a set cadence, and update it when a new AI feature launches or an existing one changes what it generates. Mapping each row to a paragraph and a role is the input counsel needs — the inventory organises the question, it does not answer it. Confirm scope and roles with qualified counsel.
Common questions
What should an AI systems inventory include for Article 50?
At minimum, each AI system, its output types, whether you are provider-side or deployer-side, and which Article 50 paragraph it might engage, plus the disclosure or marking approach in place. It organises the analysis; it does not determine your obligations, which 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.