The full text of Article 50, a plain-English translation, the three scenarios it covers, compliant and non-compliant examples, and copy templates you can use today.
Article 50 of Regulation (EU) 2024/1689 is titled "Transparency obligations for certain AI systems." Here is the operative text of the three main obligations, with plain-English translation immediately following each:
Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the context and the circumstances of use.
Plain English: If your product has a chatbot, AI assistant, or any conversational AI feature, users must know it is AI before or when the conversation starts. You cannot assume they already know. The exception ("obvious from context") is narrower than founders typically assume — see the section on exceptions below.
Providers and deployers of AI systems referred to in points (a) and (b) of paragraph 1 of Article 6 shall inform the natural persons exposed to those systems of the operation of those systems.
Plain English: If your product uses AI to recognise emotions (from facial expressions, voice, text sentiment) or categorise people by biometric characteristics (age, gender, ethnicity from appearance), users must be told this is happening. This applies to a narrower set of products — HR tools, physical security, retail analytics — and is less likely to apply to most SaaS founders reading this guide.
Deployers of an AI system that generates or manipulates image, audio or video content constituting a deep fake shall disclose that the content has been artificially generated or manipulated. [...] Deployers of AI systems that generate or manipulate text [...] shall disclose that the text has been artificially generated.
Plain English: Content generated by AI — text, images, audio, video — that is presented to users must be labeled as AI-generated. This applies to outputs your app surfaces to end users, not to AI you use internally. An AI-generated report shown to a customer requires a label. An AI-assisted internal summary your team uses does not require disclosure to external users, though best practice is to label it anyway.
What triggers it: Any AI system that converses with users in natural language — a support chatbot, an onboarding assistant, an AI Q&A feature, a copilot, an in-app help widget powered by an LLM.
What you must do: Ensure users are informed they are interacting with AI before or at the start of the interaction. The disclosure must be clear and visible — not buried in terms of service, not in a hover tooltip, not in an FAQ.
When it applies: This scenario applies to the vast majority of AI-powered SaaS products. If you call the OpenAI, Anthropic, or Google AI API to respond to user messages, this scenario applies to you.
The "authorised representative" exception: Article 50(1) includes an exception for AI systems that have been authorised by a natural person "to represent them." This covers, for example, an AI email assistant that users explicitly configure to reply on their behalf — the people receiving those replies do not need disclosure because the user has actively configured and authorised the AI representation. This is a narrow exception and does not apply to most product chatbots.
What triggers it: Any AI-generated text, image, audio, or video that your product surfaces to end users. This includes: AI-written summaries, reports, or recommendations displayed to users; AI-generated social media content that your platform posts or suggests; AI-written emails or messages your platform sends on behalf of users; AI-generated images in content creation tools.
What you must do: Label the AI-generated content in a way that is visible to the user. A badge, footer note, or inline label meets the requirement. The content must be labeled — not just disclosed in a privacy policy.
The human-significant-edit exception: EU guidance indicates that content where a human has made "significant" editorial changes and takes responsibility for the final output has a reduced labeling obligation. However, the default position should be: if an LLM generated the core content, label it. The cost of a label is zero; the cost of a complaint investigation is not.
Machine-readable format: The Regulation also requires machine-readable disclosure — an HTML meta tag or structured data element identifying content as AI-generated satisfies this. The European AI Office is expected to publish a technical standard for this format before August 2, 2026.
What triggers it: AI systems that analyse users' facial expressions, voice patterns, or biometric identifiers to infer emotions, intentions, or demographic characteristics. Examples: a video interview platform that scores candidate emotional responses, a retail tool that analyses shoppers' expressions, an HR tool that assesses employee sentiment from facial video.
What you must do: Notify users that they are being subjected to an emotion recognition or biometric categorisation system before it runs. Passive disclosure (e.g., a privacy policy mention) is not sufficient — users must be actively informed.
Relevance to most SaaS founders: This scenario applies to a minority of products. If your product does not analyse users' biometric data or emotion signals, you are not affected by this obligation.
The following examples show what compliance and non-compliance look like for a typical AI-powered SaaS with a customer support or onboarding chatbot. The product in these examples is a hypothetical SaaS with an LLM-powered assistant.
The EU AI Act includes two exceptions to the disclosure obligation: the "obvious from context" exception for AI interaction disclosure, and the "significant human edit" consideration for AI-generated content. Both are narrower than they appear in practice.
| Scenario | Disclosure required? | Reasoning |
|---|---|---|
| AI company's website chatbot, where the entire product is an AI | Likely not required | The AI nature is the central marketing message — context makes it obvious |
| AI writing assistant where every feature is explicitly described as AI | Likely not required | Product category makes AI nature obvious to a typical user |
| Customer support chatbot on a SaaS product | Required | Users may reasonably expect a human support agent |
| Onboarding assistant in a product where AI is a feature, not the product | Required | The AI nature of the specific assistant is not obvious from the broader product context |
| AI-powered in-app search or autocomplete | Required | Search feels like a utility feature — users do not assume it is conversational AI, but the regulation's scope is broad |
| Chatbot on a legal, medical, or HR platform | Strongly required | Users in these contexts have legitimate expectations of human professional interaction — regulators are likely to scrutinise this category closely |
The European AI Office's published guidance states that the "obvious from context" exception should be interpreted narrowly. If there is genuine ambiguity about whether a user would know they are interacting with AI, the disclosure is required. Given this, the practical standard for most SaaS founders is: always disclose.
The disclosure required by Article 50(1) is a sentence of copy and a UI element. The implementation time is measured in minutes. There is no argument for omitting it — the compliance benefit is absolute, the implementation cost is near-zero, and the design impact can be made neutral or even positive (an "AI assistant" label often increases user trust by setting accurate expectations).
The principle: when in doubt, disclose. Err on the side of transparency. The regulation is not punishing AI — it is requiring honesty about AI. That is something well-designed products should do regardless of regulatory obligation.
The following templates are designed for immediate use. Adapt the product name and context as needed. Each template satisfies the Article 50(1) requirement on its own.
role: "assistant" message added before your first role: "user" message. This ensures every conversation starts with the disclosure automatically, regardless of how users access the feature.
Use this checklist to confirm your Article 50 compliance before August 2, 2026. Each item maps to a specific disclosure obligation.
Reading this guide gives you the knowledge. The next step is knowing which of these items your product currently passes and which it fails. The Compliance Score scans your live app and privacy policy against 52 checks — including every Article 50 requirement — and returns a pass/fail report in under 3 minutes.
For each failed check, you receive a specific description of the gap, the regulation section it maps to, and an implementation recommendation. The AI disclosure checks specifically identify: whether a disclosure is present in your chat interface, whether it appears before interaction begins, and whether the language used satisfies the "clear" standard under Article 50 guidance.
The full guide to what the EU AI Act requires — beyond Article 50, including how it intersects with GDPR and what you need to do this week vs this month — is at EU AI Act: The Complete Compliance Guide for SaaS Founders.
52-point automated scan of your live app and privacy policy. AI disclosure, content labeling, GDPR gaps, cookie consent, security headers. Pass/fail on every check — fix list and templates included. Your $799 is credited toward DFY implementation.
Run Compliance Score — $799 See all plansRelated: EU AI Act: The Complete Compliance Guide for AI-Powered SaaS Founders (August 2026) — all obligations, the enforcement timeline, fines, and a full step-by-step implementation plan.
Sources: Regulation (EU) 2024/1689 of the European Parliament and of the Council (EU AI Act), Article 50; European AI Office, "Guidance on the Application of Article 50 Transparency Obligations" (draft), May 2026; European Parliament Research Service, "EU AI Act Implementation Timeline," 2025. This article provides general information, not legal advice. For advice specific to your product, consult a qualified EU AI Act compliance practitioner.