Transparency Obligations Under the EU AI Act

See also our full guide to the EU AI Act for the wider context.

What are the transparency obligations?

The transparency obligations in Article 50 of the AI Act aren't about whether an AI system is allowed in the first place. They're about making sure people can know when they're dealing with AI, or when content has been created or manipulated by AI. The rules have applied since 2 August 2026 and were not affected by the later deferral of the high-risk deadlines.

The European Commission published draft guidelines on Article 50 in May 2026 and adopted the final version on 20 July 2026, just days before the obligations took effect. There is also a voluntary “Code of Practice on Transparency of AI-Generated Content”, published on 10 June 2026, which can help providers and deployers meet the labelling and disclosure requirements in practice, but it's guidance, not a legal requirement in itself.

Who do the rules apply to?

Article 50 addresses both providers and deployers, but which obligation falls on whom depends on which part of the article is in play:

• Providers of AI systems that interact directly with people (chatbots, for example), and providers of AI systems that generate synthetic audio, image, video, or text content.
• Deployers of emotion recognition or biometric categorisation systems, and deployers of systems that create deepfakes or generate AI text published to inform the public on matters of public interest.

AI interactions must be recognisable

When an AI system is designed to interact directly with people (typically a chatbot or similar), it must be built so it's clear to the person that they're talking to AI, unlessthat's already obvious from the context. This also covers agent-based AI carrying out tasks more autonomously.

AI-generated content must be labellable

Providers of AI systems that generate synthetic audio, image, video, or text content must ensure the output is marked in a machine-readable format so it can be recognised as artificially generated or manipulated.

Emotion recognition and biometric categorisation

Deployers using AI for emotion recognition or biometric categorisation must inform the people exposed to it that the system is in use. This part of Article 50 applies generally, but sits alongside the separate, stricter restrictions that already apply to certain uses in workplace and education settings.

Deepfakes and AI-generated content of public interest

Deployers using AI to create or manipulate image, audio, or video content that constitutes a deepfake (content resembling real people, places, or events that would otherwise appear authentic) must disclose that the content has been artificially generated or manipulated. The same applies to AI-generated or manipulated text published to inform the public on matters of public interest, subject to certain exceptions, for example where there is editorial responsibility and human review of the content, or for artistic and satirical works, where disclosure must be given in a way that doesn't unduly hinder the work. There's also an exception for use that's legally authorised to detect, prevent, or investigate crime.

What should your business consider in practice?

• Do you use chatbots or other AI systems that interact directly with customers?
• Do you generate content with AI that others might otherwise assume is human-made?
• Do you use AI for emotion recognition or biometric categorisation, in customer service or security, for example?
• Do you have processes in place to ensure AI-generated or manipulated content gets labelled or disclosed correctly?

This is exactly the kind of practical overview Complaia is also working to make easier to keep track of in the upcoming AI compliance platform.

Important to know

This page provides general information about Article 50 and is not legal advice. How the rules apply to a specific AI system depends on the precise circumstances, and we recommend seeking professional legal advice where it genuinely matters. Prepared and reviewed by Complaia based on Article 50 of the AI Act and the European Commission's guidelines of 20 July 2026.

The Complaia Guide: a deeper breakdown is on its way

Now that the rules apply, we're working on a focused, practical guide that goes even deeper on the transparency obligations specifically, written for businesses, not lawyers. It covers the transparency obligations only, not the full AI Act. It isn't ready yet, and it's general information rather than legal advice.

Want to be notified when the Complaia Guide is ready?