Article 50: AI Transparency Rules for Your Product

Article 50 of the EU AI Act is the part most product teams will encounter first. It applies to limited-risk systems — chatbots, emotion recognition, biometric categorisation, and any AI that generates or manipulates content. The obligations are simple: tell users when AI is involved, label synthetic media in machine-readable form, and do it in clear, plain language at the point of interaction.

The four trigger scenarios

• User interacts with an AI system (chatbot, voice agent) — disclose unless it is obvious from context
• User is exposed to emotion recognition or biometric categorisation — explicit disclosure and, in many cases, consent
• Synthetic content is generated (text, image, audio, video) — machine-readable marking
• Deepfakes or AI-generated content depicting real people, places or events — visible labelling unless artistic exception applies

What disclosure has to look like

Clear, distinguishable, accessible at the latest at the first interaction. Not buried in terms of service. Not in a colour-on-colour footer. The Commission has not prescribed exact wording, but the practical floor is: a short label users cannot miss before they engage.

Patterns that pass

Chatbots. A persistent label in the chat window: 'You are chatting with an AI assistant. Responses may be inaccurate.' First message includes the same line. Avatar and name visibly distinguish from a human.

Voice agents. Spoken disclosure in the first turn: 'Hello, this is an automated AI assistant from Acme. Calls may be recorded.' Repeat if the user asks 'am I speaking to a person?'

AI-generated images and video. Visible label or watermark on the asset itself, plus C2PA-style cryptographic provenance metadata embedded in the file. Major model providers now emit C2PA by default — make sure you do not strip it in your pipeline.

AI-generated text published as content. Visible disclosure where the text is presented (article byline, post footer). Internal-use AI drafts that a human edits and publishes do not require disclosure under current guidance.

Common mistakes

Putting the disclosure in the privacy policy. That is not Article 50 compliant — it has to be at the point of interaction. Disclosing once at sign-up and never again. Stripping provenance metadata from generated images during your CDN resize step. Treating 'everyone knows it is AI' as an exception — the obviousness exception is narrower than people assume.

Documentation you need to keep

• Inventory of every AI surface in your product and which Article 50 trigger applies
• Screenshots or recordings of the disclosure at the point of interaction
• Policy decisions on edge cases (translation, summarisation, search ranking) with rationale
• Provenance signing setup for any synthetic media you generate or distribute

That's exactly what we built your Hypergility AI companion for — induced with our team and innovation hub partners' domain expertise, designed to challenge your thinking rather than rubber-stamp it.