Guides · Article 50 · EU AI Act
What SaaS companies should know about Article 50
Many SaaS products now ship AI features — a support chatbot, a writing assistant, an image or voice generator, or analytics that infer things about people. Several of these can touch Article 50 of the EU AI Act, which sets transparency duties for certain AI systems. This guide gives a general overview for SaaS teams. It is informational only, not legal advice, and does not determine whether the Act applies to your product.
Which SaaS features Article 50 tends to touch
Article 50 is organised by the kind of AI system rather than by industry, so the useful exercise is to map each AI feature to the paragraph it might engage:
- AI chat or voice assistants that talk to end users → Article 50(1), provider-side disclosure that people are interacting with an AI system.
- Features that generate synthetic audio, image, video, or text → Article 50(2), provider-side machine-readable marking of outputs.
- Features that infer emotion or categorise people from biometric data → Article 50(3), deployer-side notice plus EU data-protection law.
- Features that create deepfake image, audio, or video → Article 50(4), deployer-side disclosure that content is artificially generated.
Provider, deployer, or both — and who your customers are
SaaS raises a wrinkle: for the same feature you may be a provider (you built and offer the system) while your customer is a deployer (they use it with their own users). 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 qualified counsel — see our provider-vs-deployer guide for the split.
What SaaS teams commonly document
- An inventory of every AI feature and the output types it can produce.
- For each feature, which Article 50 paragraph it might engage and whether you are provider-side, deployer-side, or both.
- The disclosure or marking approach for each, and where it surfaces in the product.
- How disclosures meet the timing and accessibility points in Article 50(5).
- Any carve-outs you may rely on, with the rationale, for counsel's review.
Common questions
Does a SaaS support chatbot need an AI disclosure?
Article 50(1) addresses AI systems intended to interact directly with people, subject to an exception where the AI nature is already obvious. Whether it applies to your chatbot is fact-specific. Our free scope check gives an informational indication; 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.