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Regulation Published · 12 September 2026

Article 50: the transparency duty that applies to your chatbot

If you have a customer-facing chatbot or publish generated content, Article 50 of the AI Act already applies to you. And if the system was deployed before August 2026, your deadline is 2 December.

5 min read

Of the whole EU AI Act, Article 50 is the one most companies breach without realising. Not through negligence: because it isn’t labelled “high risk” and almost everyone assumed the regulation was about something else.

What it requires

Article 50 places transparency duties on AI systems that interact with people or generate content. In practice, four things:

SituationWhat you must do
An AI system interacts with a personTell them they are interacting with an AI, unless it is obvious
You generate synthetic audio, image, video or textMark the output as artificially generated, in machine-readable form
You detect emotions or perform biometric categorisationInform the people exposed to it
You generate deepfakesDisclose that the content has been generated or manipulated

The nuance most often missed is the machine-readable marking. A visual notice to the user is not sufficient on its own when the requirement is that the output be technically identifiable.

The dates

General application of the Regulation landed on 2 August 2026, and Article 50 with it.

There is one exception with its own deadline: systems generating synthetic content that were already on the market before 2 August 2026 have until 2 December 2026 to comply with Article 50(2).

If you deployed a chatbot or content generator in 2024 or 2025 and haven’t touched it since, that is your deadline. Weeks, not quarters.

What usually goes wrong

In the reviews we run, the failures repeat:

The notice exists, in the wrong place. A line in the privacy policy informs nobody. The duty is that the person knows while interacting, not that they could find out if they investigated.

The chatbot has a human name and a human sign-off. “Hi, I’m Laura from the support team” is precisely what the rule exists to prevent. You can give an assistant personality without pretending it is a person.

Generated content ships unmarked. Product descriptions, email drafts, catalogue images. If they are published as synthetic content, they are in scope.

Nobody maintains the inventory. You complied on deployment day and six months later there are three new integrations nobody reviewed.

What compliance costs

Very little, and that is the best news in the whole Regulation. For a typical mid-sized company:

  • A line of notice when the chat opens and in the assistant’s first message.
  • Provenance metadata on generated content you publish.
  • A sheet listing your AI systems, their purpose and their owner.
  • A quarterly review of that sheet.

That is days of work, not months. The risk is not in the difficulty, it is in never having realised it applied.

A recommendation that goes beyond the rule

Disclosing that an AI is behind the conversation does not hurt conversion: it helps. Users are reasonably good at detecting when something isn’t human, and finding out on their own breeds far more distrust than being told up front.

Complying here is one of the few regulatory duties that pays for itself.

Sources

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