Guides · Article 50 · EU AI Act
An EU AI Act Article 50 transparency checklist
Once you know which parts of Article 50 might touch your AI systems, the next step is turning each obligation into something teams can document. This guide gives a checklist, organised by the four paragraphs, mapping each to what teams commonly record. It is informational only, not legal advice, and completing a checklist does not by itself establish that an obligation is met.
Before the paragraph-by-paragraph list
- Inventory every AI system and AI feature you run, and the output types each can produce.
- For each, note whether you are provider-side, deployer-side, or both.
- Match each system to the Article 50 paragraph(s) it might engage.
- Confirm scope questions and roles with qualified counsel — they are fact-specific.
Article 50(1) — chatbots and direct interaction (providers)
- Draft the disclosure that users are interacting with an AI system.
- Confirm it appears at or before the first interaction (Article 50(5)).
- Record how it meets applicable accessibility requirements.
- If relying on the 'obvious' exception, document the reasoning.
Article 50(2) — synthetic content (providers)
- Inventory each output type the system generates (audio, image, video, text).
- Select and record the machine-readable marking method for each.
- Document why the method is effective, interoperable, robust, and reliable so far as technically feasible.
- If relying on the assistive-editing or no-substantial-alteration carve-out, record the rationale.
Article 50(3) and 50(4) — emotion recognition and deepfakes (deployers)
- For emotion-recognition or biometric-categorisation systems: draft the notice to exposed persons and cross-reference your EU data-protection documentation.
- For deepfakes: draft the 'artificially generated or manipulated' disclosure and confirm clear, distinguishable delivery at or before first exposure.
- For evidently artistic or creative works, document the limited-disclosure approach.
- Note any law-enforcement authorisation relied on, with safeguards, and route everything to counsel.
Common questions
Does finishing this checklist mean I'm compliant with Article 50?
No. The checklist helps organise documentation, but the facts of your deployment and counsel's review govern whether an obligation is met. Treat it as a starting point, not a determination, and verify 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.