Article 50 transparency check: become transparency-compliant in time
The transparency obligations of Article 50 apply from 2 August 2026 and have not been postponed. While the high-risk regime moves out, transparency is the next obligation that actually applies. In a short check we map your chatbots, generative AI and AI content and record which disclosure, marking and information duties are missing.
Transparency check
1 week
From AI use to demonstrable transparency
Overview of chatbots, generative AI and AI content
Per use case: which Article 50 duty applies
Disclosure, marking and information texts
Action list to be compliant before 2 August 2026
Transparency has not been postponed
The political agreement on the Digital Omnibus moves the Annex III high-risk regime to 2 December 2027. That agreement is not yet applicable law: until publication in the Official Journal, 2 August 2026 formally stands. The transparency obligations of Article 50 have not been postponed in any case. For organizations with chatbots or generative AI and no high-risk systems, transparency is therefore the next obligation that actually applies on 2 August 2026.
The four transparency obligations of Article 50
Article 50 touches almost every organization that deploys AI toward people, even without high-risk systems. We test your use cases against the four duties.
Chatbot and AI interaction disclosure
People must know they are communicating with an AI system, unless that is obvious. Applies to customer service bots, virtual assistants and conversational AI.
Marking of AI content
AI generated or manipulated image, audio or video content (including deepfakes and synthetic content) must be machine-readable marked as artificially generated.
Emotion recognition and biometric categorization
People exposed to emotion recognition or biometric categorization must be informed about it.
AI text of public interest
AI generated text published to inform the public on matters of public interest must be recognizable as such.
Transition period for existing generative AI: for the machine-readable marking under Article 50(2), the political agreement of May 2026 provides a transition period until 2 December 2026. That agreement has not yet been formally adopted. The disclosure and information duties apply in full from 2 August 2026.
When this check fits
This check is for organizations with chatbots or generative AI and no high-risk systems, that need to be transparency-compliant before 2 August 2026.
You use chatbots or AI assistants
Customer service bots, conversational AI or virtual assistants where it is unclear whether disclosure is handled correctly.
You publish AI content
Marketing, social, product imagery or text with generative AI, without marking and recognizability being recorded.
No high-risk, but a deadline
You likely have no high-risk systems, but transparency applies from 2 August 2026 and needs concrete action now.
What the check delivers
Inventory of chatbots, generative AI and AI content within scope
Per use case: which Article 50 obligation applies
Role determination: whether you act as provider or deployer per use case
Gap overview: which disclosure, marking or information is still missing
Concrete disclosure and information texts for bots, content and interfaces
Approach for machine-readable marking of AI content and deepfakes
Action list with owner and priority to be compliant before 2 August 2026
Note on the transition period for existing generative AI
Approach in 1 week
Scope and intake
We define which chatbots, generative AI use cases and AI content fall within the transparency scope.
Inventory
We map per use case how AI is deployed toward users, customers or the public.
Test against Article 50
We connect each use case to the right transparency duty and determine whether you are provider or deployer.
Texts and marking
We deliver disclosure and information texts and an approach for machine-readable marking of AI content.
Action list
You get a concrete list of actions, owners and priorities to be transparency-compliant before 2 August 2026.
Who this works for
Marketing and communications
Teams that use generative AI for content, imagery or social and want marking and recognizability handled properly.
Customer service and digital
Teams with chatbots, virtual assistants or conversational AI in customer channels.
Legal, privacy and compliance
Teams that want to translate the transparency duties of Article 50 into concrete texts and evidence.
Product and engineering
Teams that need to build disclosure and machine-readable marking into interfaces and output.
Afterwards you know
Which Article 50 duty applies per use case
Whether you are provider or deployer per use case
Which disclosure and marking is still missing
Which texts and interface changes are needed
Which actions must be done before 2 August 2026
Logical next steps
AI Act readiness and gap analysis
For a broader view of AI systems, roles, risks and evidence in one roadmap.
View routeEU AI Act deadline 2026
For the full picture toward 2 August 2026: which obligations apply when.
View routeAI inventory setup
For a compact inventory of AI systems with owner, purpose and evidence status.
View routeBackground and deadlines
Deeper analysis on the Responsible AI Platform about the transparency deadline and the postponement of the high-risk regime:
Frequently asked questions
Is Article 50 really not postponed?
The transparency obligations of Article 50 apply from 2 August 2026 and have not been postponed. The political agreement on the Digital Omnibus moves the Annex III high-risk regime to 2 December 2027, but that agreement is not yet applicable law. Until publication in the Official Journal, 2 August 2026 formally stands. Transparency is therefore the next obligation that actually applies.
Does this apply if we have no high-risk AI?
Yes. Article 50 is separate from the high-risk regime. As soon as you deploy chatbots, generative AI or AI content toward people, the transparency duties apply, even without high-risk systems.
What is the transition period for existing generative AI?
For the machine-readable marking under Article 50(2), the political agreement of May 2026 provides a transition period until 2 December 2026. That agreement has not yet been formally adopted. The disclosure and information duties apply in full from 2 August 2026.
Is this legal advice?
No. This is a practical transparency check. We structure use cases, duties and concrete texts so marketing, communications, legal, IT and management can act in a focused way. For formal legal advice, involve legal counsel.
How much internal time does this require?
Usually 1 to 2 short interviews, an overview of your chatbots and generative AI use cases and one review moment. We do most of the drafting.
Become transparency-compliant before 2 August 2026.
Start with the transparency check. We determine which chatbots, generative AI and AI content belong in scope and which Article 50 duties are missing.