EU AI Act Article 50 compliance checklist

The checklist

1. Reach: does the feature or its output reach people in the EU? Non-EU providers are covered if the output is used in the EU.
2. Role per feature: provider (you build it or ship it under your name) or deployer (you use it under your authority)?
3. Art. 50(1) chatbots, agents, avatars (providers): people are told it's AI from the start of the first interaction, unless obvious to a reasonably well-informed person. The Commission reads this exception restrictively.
4. Art. 50(2) generated text/image/audio/video (providers): machine-readable marks, detectable as AI. Not covered: assistive standard editing, source code, machine-to-machine output. Systems on the market before 2 Aug 2026 have until 2 Dec 2026 for this point only.
5. Art. 50(3) emotion recognition / biometric categorisation (deployers): inform people exposed.
6. Art. 50(4) deepfakes (deployers): visible or audible label at first exposure; a machine-readable mark alone is not enough. Evidently artistic or satirical works: disclose without hampering the work.
7. Art. 50(4) public-interest text (deployers): label unless it had real human review or editorial control under someone's editorial responsibility. Spell-checks don't count.
8. Art. 50(5): clear, distinguishable, accessible, no later than first interaction or exposure.
9. Good practice: keep dated screenshots and wording; re-check after changes.

Penalties

Up to EUR 15M or 3% of worldwide turnover, whichever is higher; for SMEs, whichever is lower (Art. 99(4)(g), 99(6)).

FAQ

Sources

• https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act
• https://digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations
• https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-50
• https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99