Article 50 transparency

What to retain in an Article 50 transparency evidence record

An Article 50 transparency evidence record should preserve the facts a reviewer needs before deciding how disclosure obligations apply. For buyer or compliance review, this usually means:

• the system or feature name and intended user interaction;
• whether the review concerns direct interaction (Art. 50(1)), provider-side synthetic-content marking (Art. 50(2)), deployer-side emotion recognition or biometric categorisation notice (Art. 50(3)), or deployer-side deepfake / public-interest text disclosure (Art. 50(4));
• the provider/deployer role being reviewed;
• draft notice text, placement, timing, language, and accessibility assumptions;
• any "unless obvious" rationale, if considered;
• reviewer, owner, date, version, and unresolved NEEDS REVIEW items.

This page helps organise the evidence record. It does not determine Article 50 applicability, notice adequacy, or legal sufficiency. Commission draft guidelines on Article 50 transparency obligations were published in May 2026 and have not yet been finally adopted; review records against the current draft and any final adopted guidance when available.

The obligation

Article 50 of the EU AI Act imposes transparency obligations on deployers and providers of certain AI systems, regardless of risk tier. These include systems that interact directly with natural persons (chatbots, voice assistants), systems that generate synthetic content (text, image, audio, video), and systems that process biometric data for categorisation or emotion recognition.

Article 50 includes several transparency-related obligations, including direct-interaction disclosure, provider-side marking of AI-generated or manipulated synthetic content, deployer-side notices for emotion recognition or biometric categorisation, and deployer-side disclosure for deepfakes or certain AI-generated public-interest text. The applicable obligation depends on the system type, role, deployment context, and source status of current guidance.

What the kit provides for this use case

The EU AI Act Compliance Starter Kit includes artifacts designed to support Article 50 documentation work:

• Article 50 Decision Record — structured template for recording which transparency obligations apply to your system and why
• Article 50 Draft Disclosure Notices — starting-point notices for chatbot/conversational AI, deployer-side deepfake or public-interest text disclosure, and "unless obvious" exception documentation, to be adapted to your context. Article 50(2) provider-side synthetic-content marking is a technical marking duty documented through the Article 50 Decision Record, not a substitute UI notice. Biometric categorisation and emotion-recognition contexts are handled through the Article 50 Decision Record and require context-specific review; this kit does not include a dedicated biometric notice template.
• Intended Purpose Statement — formal description of system purpose that anchors transparency decisions
• Risk Tier Rationale Memo — risk classification documentation that contextualises your Article 50 obligations
• AI Literacy Evidence Log — record structure for staff awareness and training on AI transparency

All templates are designed to be adapted. They provide the documentation structure and decision prompts — not jurisdiction-specific legal determinations.

Reference

Article 50 applicability evidence map — mapping of the four Article 50 sub-obligations to evidence, artifacts, review owners, and red flags.

Scope boundary

The kit covers the documentation structure and decision prompts needed to implement and record transparency obligations in Limited and Minimal Risk contexts. It does not provide legal determinations on what constitutes adequate disclosure for your specific system. It does not cover High-Risk conformity assessment or systemic-risk GPAI provider obligations. Buyers must adapt materials to their context and obtain qualified legal review where appropriate.