EU AI Act Article 50 Transparency Obligations

Article 50 of Regulation (EU) 2024/1689 assigns different transparency duties to providers and deployers. Providers of systems intended to interact directly with people must design them to inform users they are interacting with AI unless that is obvious from context. Providers of systems generating synthetic audio, image, video or text must mark outputs in machine-readable form and make them detectable as artificial, to the extent technically feasible and subject to specific exceptions. Deployers have separate duties. They must inform exposed people when using emotion-recognition or biometric-categorisation systems, subject to exceptions. A deployer using deepfake image, audio or video content must disclose its artificial generation or manipulation. Artistic, creative, satirical, fictional or analogous works still require disclosure, but in an appropriate way that does not hamper enjoyment. For AI-generated or manipulated text published for the purpose of informing the public on matters of public interest, deployers must disclose its artificial generation or manipulation. Disclosure is not required where the content has undergone human review or editorial control and a natural or legal person holds editorial responsibility for the publication. Information should be clear, distinguishable, accessible and given by first interaction or exposure. Article 50 applies generally from 2 August 2026. Regulation (EU) 2026/1744, now in force, adds a narrow transition: providers of synthetic-content systems placed on the market before 2 August 2026 must take necessary steps to comply with paragraph 2 by 2 December 2026. This transition concerns provider marking under Article 50(2), not every Article 50 duty. Machine-readable provider marking is distinct from a deployer’s visible disclosure.