EU AI Act Article 50: Transparency Obligations Explained

What does Article 50 of the EU AI Act regulate?

Article 50 of the EU AI Act defines when people must be told that they are dealing with artificial intelligence. The provision is part of Regulation (EU) 2024/1689, the European AI Act, and applies from 2 August 2026. Unlike the rules for high-risk AI, Article 50 covers many everyday applications: website chatbots, phone assistants, digital avatars, image and video generators, and AI-generated text.

The idea is simple: anyone talking to a machine or seeing artificially generated content should be able to recognise it. Article 50 does not ban any technology; it requires openness. Depending on the case, the obligations fall on providers, meaning companies that develop an AI system or place it on the market under their own name, or on deployers, meaning companies that use an AI system under their own authority.

Under Article 50, the information must be given at the latest at the time of the first interaction or exposure, in a clear and distinguishable manner, and must take accessibility requirements into account.

Which obligations apply to providers and deployers?

Article 50 contains several obligations that concern different roles and applications. For companies it helps to map each of their own AI applications to one of these categories:

• Interaction with people (providers): AI systems that interact directly with people must be designed so that those people are informed they are interacting with AI, unless this is obvious to a reasonably well-informed person.
• Synthetic content (providers of generative AI): AI-generated audio, image, video or text must be marked in a machine-readable format and be detectable as artificially generated or manipulated. There are exceptions, for example for purely assistive editing functions that do not substantially alter the input.
• Emotion recognition and biometric categorisation (deployers): the people exposed must be informed about the operation of such a system.
• Deepfakes (deployers): anyone generating or manipulating image, audio or video content that resembles real people, places or events must disclose that it was artificially generated or manipulated.
• AI-generated text (deployers): text published to inform the public on matters of public interest must be disclosed as AI-generated, unless it has undergone human review or editorial control and a person or company holds editorial responsibility.

What does Article 50 mean for chatbots, voice agents and AI avatars?

For chatbots, voice agents and interactive AI avatars, the key obligation is disclosing the AI interaction. A website chatbot should make clear that an AI is answering, for example in the chat window and in the first message. A voice agent on the phone should introduce itself as an AI assistant at the start of the call, because callers can rarely tell whether a person or a machine is speaking.

With AI avatars two aspects come together. A video avatar that talks to visitors and answers questions interacts with people and must be recognisable as AI. If the avatar also looks like a real, existing person, it may count as a deepfake, which makes labelling it as artificially generated all the more important. For evidently artistic, satirical or fictional works, Article 50 provides a lighter disclosure duty that should not hamper the display of the work.

In practice a clear sentence at the start works well, such as “I am an AI assistant for …”, supported by a visible notice in the interface and a transparency page explaining where AI is used and how people can reach a human.

When must deepfakes and AI-generated text be labelled?

Under Article 50, deepfakes must be disclosed whenever AI-generated or AI-manipulated image, audio or video content resembles real people, objects, places or events and could falsely appear authentic. This includes realistic promotional videos with synthetic presenters, cloned voices or photos that recreate real scenes. Purely abstract graphics or clearly stylised illustrations usually do not fall under the deepfake definition.

For AI-generated text the obligation is narrower. It covers text published to inform the public on matters of public interest, such as news or articles on societal topics. If such text has been reviewed by people and a person or company holds editorial responsibility, the labelling duty does not apply. Product copy or internal documents are usually not covered, although voluntary transparency can still make sense.

Separately from deployers’ duties, providers of generative AI systems must ensure their outputs are marked in a machine-readable way, for example through watermarks or metadata. Companies using off-the-shelf tools should therefore check whether their provider supplies this marking and whether it survives their own further processing.

What is the current status of guidelines, the code of practice and deadlines?

The European Commission has accompanied Article 50 with guidelines and a code of practice. To our knowledge as of September 2026, the Commission published final guidelines on the transparency obligations in July 2026. A Code of Practice on the transparency of AI-generated content was also developed; it describes concrete measures for marking and labelling and has been confirmed as an adequate means of demonstrating compliance. Signing the code is voluntary.

The so-called AI Omnibus, an amendment package to the EU AI Act, introduced a transitional period for machine-readable marking under Article 50(2): to our knowledge, for generative AI systems already on the market before 2 August 2026, this obligation only applies from 2 December 2026. The obligation to inform people that they are interacting with AI is not affected and applies from 2 August 2026.

Guidelines, codes and details may be adjusted further. Check the current status directly with the European Commission and in the Official Journal of the EU before making decisions.

What should companies do now, and how does Klarframe implement Article 50?

For most companies, Article 50 can be tackled with a manageable review. These steps help to get oriented:

• Create an inventory: where does the company use AI that interacts with people or generates content? Chatbot, phone assistant, avatar, image and video generation, text.
• Clarify the role: is the company a provider, a deployer or both? This determines which obligations apply.
• Design notices: disclose the AI interaction at the start, in clear and accessible wording.
• Review content: label realistic AI images, voices and videos, and preserve the markings from your tools.
• Offer human contact: name a clear route to a person, for example by email or contact form.
• Document: record decisions and notices, and update them when new guidance appears.

Does this guide replace legal advice?

Klarframe discloses AI interactions as required by the EU AI Act. The AI assistant Emma introduces herself as AI, realistic AI-generated or AI-manipulated image, audio and video content is labelled directly next to the content, and anyone who prefers a person can reach the team by email or contact form. The details are on the Klarframe transparency page at https://klarframe.com/en/ki-transparenz. In client projects such as voice agents and video avatars, the AI notice is part of the conversation and interface design.

Not legal advice: this guide summarises Article 50 in general terms and to the best of our knowledge. It does not replace individual legal advice or a review of your specific case. Whether and how the obligations apply to your company should be clarified with a lawyer or your data protection advisor.

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