Article 50 of the EU AI Act has applied since 2 August 2026. If your product runs a chatbot, publishes AI-generated content, or uses emotion recognition, the transparency duties already apply to you.
Fines reach €15 million or 3% of worldwide annual turnover, whichever is higher.
One public page. No signup, no card, nothing stored beyond rate limiting.
Four things. A system that interacts with a person must say it is AI. Synthetic audio, image, video or text must be marked in a machine-readable format. Deepfakes must be labelled. People exposed to emotion recognition or biometric categorisation must be told. It applies to providers and deployers, wherever they are based, if the output reaches people in the EU.
The EU AI Act's Article 50 transparency obligations have applied since 2 August 2026. If your product uses a chatbot, generates or manipulates synthetic content, runs emotion recognition or biometric categorisation, they apply to you now. Systems already on the market before that date have until 2 December 2026 to meet the Article 50(2) marking duty specifically.
Part of it was. Stand-alone high-risk obligations (Annex III) were postponed from 2 August 2026 to 2 December 2027 by Regulation (EU) 2026/1744 (OJ 24 July 2026, in force 27 July 2026). Article 50 was not touched by that amendment and applies now.
It fetches one public page and looks for four signals: a chatbot or virtual assistant, AI-generated content references, a personalised recommendation system, and AI-powered search. It then looks for an AI disclosure on the same page. That is the whole of it.
Machine-readable provenance marking under Article 50(2), because that lives inside the media file and not the page. Deepfake labelling, because deciding what is a deepfake is a judgement. Emotion recognition, because it usually sits behind a login. And whether your disclosure wording is adequate, which is a review question rather than a pattern match.
Up to €15 million or 3% of worldwide annual turnover, whichever is higher, for breaches of the transparency obligations. Prohibited practices under Article 5 carry up to €35 million or 7%.
Most of Article 50 is not visible from outside. Our fixed-scope Transparency Review inventories every user-facing AI surface you run, decides which paragraph of Article 50 applies to each, drafts the disclosure wording, and produces a marking plan for the 2 December 2026 deadline that covers anything you shipped before 2 August 2026.
See what the review coversCompliPilot is not a law firm and this page is not legal advice. Dates are stated as published in the Official Journal and verified on 2026-08-05 against EUR-Lex.