Guides · Article 50 · EU AI Act
Writing an AI transparency policy
Once you have inventoried your AI systems and mapped them to Article 50, many teams write an internal policy so the transparency work is repeatable rather than ad hoc. This guide outlines what such a policy commonly covers. It is informational only, not legal advice, and having a policy does not by itself establish that any obligation is met — the facts and counsel's review govern.
What an AI transparency policy tends to cover
The point of the policy is to connect each Article 50 obligation to a person, a process, and a record. Common sections include:
- Scope: which AI systems and features the policy covers, cross-referenced to your inventory.
- Roles: how you determine provider-side versus deployer-side for each system, and who owns that call.
- Disclosure and marking standards: how the organisation approaches 50(1) interaction notices, 50(2) machine-readable marking, 50(3) emotion-recognition notices, and 50(4) deepfake or public-interest-text disclosures.
- Timing and accessibility: how disclosures meet Article 50(5) — clear, distinguishable, at the latest at first interaction or exposure, and meeting accessibility requirements.
- Review: when the policy and the underlying mapping are revisited, and how carve-out reliance is documented for counsel.
Mapping obligations to owners
A policy is most useful when each obligation has an owner. Engineering may own machine-readable marking; design may own where a disclosure surfaces; legal owns the scope and role calls. Writing down who does what is what turns Article 50 from a document into a practice — without asserting that the practice, on its own, satisfies the law.
What a policy is not
A transparency policy is internal governance, not a determination of lawfulness. It does not decide whether a given system falls inside a paragraph or whether a carve-out applies — those are fact-specific questions for qualified counsel. Treat the policy as the operating layer above counsel's analysis, not a substitute for it.
Common questions
Does having an AI transparency policy make us compliant with Article 50?
No. A policy helps organise and repeat the work, but whether an obligation is met depends on the facts of each deployment and counsel's review. Treat it as internal governance and a starting point, not a determination — 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.