Guides · Article 50 · EU AI Act
Recommendation engines and EU AI Act Article 50
Recommendation engines — the systems that rank products, content, or matches for a user — are among the most common AI features online, so teams reasonably ask whether Article 50 of the EU AI Act requires a disclosure. The honest answer is that a pure ranking system may not fit any of Article 50's four situations, though that is a fact-specific reading and other parts of the Act could still apply. This guide explains why. It is informational only, not legal advice.
Article 50 is built around four specific situations
Article 50's transparency duties attach to four things: AI systems that interact directly with people (50(1), providers), systems that generate synthetic audio, image, video or text (50(2), providers), emotion-recognition or biometric-categorisation systems (50(3), deployers), and deepfake image/audio/video or public-interest text (50(4), deployers). A recommendation engine that scores and orders existing items typically does none of these — it does not converse with the user as an AI, and it does not generate synthetic content. On that description it may fall outside Article 50.
Why 'may' is the honest word
Two cautions keep this from being a clean 'no'. First, real products blend features: if the same surface also generates written explanations or chats with the user, those elements could independently engage 50(2) or 50(1). Second, and importantly, Article 50 is only the transparency slice of the EU AI Act. Other parts of the Regulation — outside Article 50 and outside this guide's scope — may still apply to a recommender depending on what it does and the context it operates in. So the accurate framing is that a recommendation engine may fall outside Article 50's transparency obligations specifically, not that the Act as a whole is irrelevant.
A practical way to check
Describe exactly what your engine does and what, if anything, it shows or says to the user beyond a ranked list. Map each element to the four situations above. Where nothing fits, document that reasoning rather than assuming; where a generative or conversational element appears, treat it on its own terms. Confirm the analysis with qualified counsel — our free scope check helps frame the mapping but does not decide whether your system is in or out of scope.
Common questions
Does a product recommendation feed need an AI disclosure?
A feed that only ranks existing items may fall outside Article 50's four situations, though that is fact-specific and other parts of the EU AI Act could still apply. If the surface also generates content or converses, those elements may engage a paragraph. 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.