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The EU AI Act in Practice

Transparency Obligations for Chatbots, Deepfakes & AI Content (Art. 50)

Art. 50 catches companies that assume “we're limited risk, so this doesn't concern us” – because transparency obligations apply regardless of risk tier, the moment one of four specific situations occurs. This module covers all four in detail.

Four practical cases – worth remembering

Try it yourself: match the category to its labelling duty

Category

Labelling duty

Four categories, one core idea

The core idea behind Art. 50 is simple: people should be able to tell when they're interacting with AI or looking at AI-generated content. This duty is entirely independent of the risk classification – it applies on top, the moment one of the following four situations occurs, regardless of whether the system otherwise counts as minimal or limited risk.

The four categories in detail

  • Chatbots and conversational systems: people must be able to tell they're interacting with an AI rather than a human – unless that's obvious anyway.
  • Emotion recognition and biometric categorisation: affected people must be informed that such a system is being used.
  • Deepfakes (synthetic images, audio, video): content that deceptively replicates or alters real people, objects, or events must be labelled as AI-generated or AI-manipulated.
  • AI-generated text on matters of public interest: if a text is published to inform the public, it must be disclosed that it's AI-generated.

Deadlines: not everything starts at the same time

Most Art. 50 obligations apply as originally scheduled on 2 August 2026. One exception: the labelling duty specifically for synthetic media (deepfakes) was pushed back four months to 2 December 2026 under the AI Omnibus – a small but practically relevant difference from the other three categories. Also important is the split by role: providers of generative systems must mark their outputs in a machine-readable format as AI-generated; deployers who publish a deepfake must additionally label it visibly for humans.

Practice section: concrete labelling for your chatbot or content

For a website chatbot, a clear, visible notice at the start of the conversation (“You're chatting with an AI assistant”) is usually enough – no elaborate certification procedure required. For AI-generated marketing content depicting real people or events, a visible, unmissable label is required, not a note buried in the imprint's small print. Purely internal use – a chat assistant only staff can see – typically doesn't trigger these public-facing obligations, since nobody outside the company interacts with the system or consumes the content. This classification doesn't replace case-by-case legal advice.

The key points

  • Transparency obligations (Art. 50) apply regardless of risk tier – they kick in on top, the moment one of four situations occurs.
  • The four categories: chatbots, emotion recognition/biometric categorisation, deepfakes, AI-generated text on matters of public interest.
  • Most obligations apply from 2 August 2026 – only labelling of synthetic media was pushed to 2 December 2026.
  • Providers must mark outputs in a machine-readable format; deployers who publish deepfakes must additionally label them visibly for humans.
  • Purely internal use with no external audience typically doesn't trigger these public-facing obligations – this classification doesn't replace case-by-case legal advice.

The EU AI Act: what companies really need to know – and what's just panic

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What do the transparency obligations under Art. 50 depend on?

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