Guides · Article 50 · EU AI Act
What martech teams should know about Article 50
Marketing-technology platforms are, increasingly, AI content engines: they generate email copy, landing-page text, images, and video, and they run conversational features inside campaigns. Because martech vendors often build the generator their customers deploy, the Article 50 role split — providers versus deployers — is central. This guide gives a general overview for martech teams. It is informational only, not legal advice, and does not determine whether the Act applies to your platform.
Content generation — Article 50(2), providers
Article 50(2) asks providers of AI systems generating synthetic audio, image, video or text to ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, with technical solutions that are effective, interoperable, robust and reliable as far as technically feasible, taking into account the specificities and limitations of the content type, costs of implementation, and the generally acknowledged state of the art (Regulation (EU) 2024/1689). A martech platform that generates campaign copy, images, or video is a natural fit for this provider-side duty. The paragraph carves out assistive standard-editing and no-substantial-alteration uses; whether your generator falls inside the paragraph is fact-specific.
Conversational features and the role split — Article 50(1)
Where a martech product includes a conversational feature that interacts directly with people — a chat-driven campaign unit — Article 50(1)'s provider-side disclosure duty may be in view. A recurring wrinkle for martech: for the same feature you may be a provider (you built the system) while your customer is a deployer (they run it with their audience). Article 50 assigns some duties to providers and some to deployers, so both you and your customers may have roles to play, and contracts often need to reflect that. These are fact-specific questions to confirm with counsel — see our provider-vs-deployer guide for the split.
Article 50 is not the whole Act for martech
Article 50 covers only the transparency obligations; depending on your systems, other parts of the EU AI Act — including high-risk-system requirements — may also apply. Confirm your full obligations with qualified counsel.
Common questions
Is a martech platform the provider or the deployer for Article 50?
It can be both, assessed per AI system: often the provider of a content generator (Article 50(2)) while its customers are deployers of the outputs. The role governs which duty applies, and it is fact-specific — confirm with qualified counsel. Our free scope check gives an informational starting point.
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.