The Article 50 compliance checklist (August 2026)

Use this checklist to prepare for the EU AI Act's transparency obligations, which apply from 2 August 2026 (Article 113, Regulation (EU) 2024/1689). Work through it feature by feature — obligations attach to individual AI systems, not companies as a whole.

Step 1 — Scope: does the AI Act reach you?

• ☐ You offer an AI system to users in the EU, or its output is used in the EU (Article 2).
• ☐ You have identified each AI feature: chatbots, generators, recommenders, biometric tools.

Step 2 — Role: provider or deployer?

• ☐ For each feature, decide if you are the provider (you develop it / ship it under your name) or the deployer (you use it under your authority) — definitions in Article 3(3) and 3(4).
• ☐ Note: building a product on top of a third-party model API usually makes you provider of your AI system and deployer of the model.

Step 3 — Chatbots (Article 50(1))

• ☐ Every AI system that interacts directly with people informs users it is an AI.
• ☐ The notice appears at the latest at first interaction, clearly and distinguishably (Article 50(5)).
• ☐ If you rely on the “obviousness” exemption, you have documented why a reasonably well-informed person would always know.

Step 4 — Synthetic content (Article 50(2), providers)

• ☐ AI-generated audio, image, video and text outputs are marked in a machine-readable format and detectable as artificially generated.
• ☐ Marking is effective, interoperable, robust and reliable as far as technically feasible (e.g. C2PA metadata, watermarking).
• ☐ If you rely on the assistive/standard-editing exemption, you documented why outputs do not substantially alter the input or its semantics.

Step 5 — Deep fakes & published text (Article 50(4), deployers)

• ☐ Realistic AI images/audio/video of real people, places or events carry a visible disclosure.
• ☐ AI-generated text published to inform the public is either labeled or passes through documented human editorial review with named responsibility.

Step 6 — Emotion recognition / biometric categorisation (Article 50(3))

• ☐ Exposed persons are informed of the system's operation.
• ☐ Personal data processing complies with the GDPR; DPIA reviewed.

Step 7 — Delivery quality (Article 50(5))

• ☐ Disclosures are clear and distinguishable — not buried in ToS or footers.
• ☐ Delivered no later than first interaction or exposure.
• ☐ Meet applicable accessibility requirements.
• ☐ Provided in the languages of your EU users.

Step 8 — Evidence

• ☐ Keep a register of AI features, roles, applicable Article 50 duties and the measures taken.
• ☐ Keep screenshots/logs showing disclosures were live (our badge dashboard tracks impressions for this reason).

Penalties for non-compliance reach €15M or 3% of worldwide annual turnover (Article 99(4)) — see our penalties guide.