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Transparency Obligations Under the EU AI Act (Articles 13 and 50)

Two different transparency regimes, easy to conflate: Article 13's design obligation for high-risk systems to be interpretable by deployers, and Article 50's standalone disclosure duties for chatbots, deepfakes, and AI-generated content — which apply regardless of high-risk status and took effect on 2 August 2026.

Key context
"Users interacting with AI systems must be informed they are doing so — unless this is obvious from the context and the circumstances of use."
EU AI Act, Article 50(1)
A simple "AI-assisted" disclosure label on a printed page, evoking the plain-language disclosure Article 50 requires people to receive when interacting with or exposed to AI systems.

Builds on AR-000200 (The EU AI Act Explained) and AR-000210 (High-Risk AI Systems) for shared vocabulary — not re-derived here. AR-000210 deferred Article 13's detail to this article.

Executive summary

What this means

Who this applies to

Regulatory context

Requirements

What organizations must do

  • Treat Article 13 and Article 50 as two separate compliance exercises with different triggers, not a single "transparency" workstream.
  • For Article 50, map each in-scope AI system against the four paragraph-level trigger conditions individually — a system can trigger more than one.
  • Check Article 50 exposure even with no high-risk AI in the portfolio — AR-000210's classification exercise is not a prerequisite.
  • Consult the Commission's published Article 50 implementation guidelines directly for practical labelling and disclosure detail.

Common mistakes

Assuming Article 50 only applies to "AI companies" or high-risk-system operators is a common and consequential mistake — any organisation running a customer-facing chatbot, publishing AI-generated marketing content, or using emotion-recognition tooling can be in scope.

Treating the Article 50(4) evidently-artistic-work exemption as a blanket carve-out for creative content is a second mistake — it only reduces the disclosure, it does not remove the duty entirely.

Assuming the Article 50(2) assistive-editing exemption covers any AI-assisted content creation is a third mistake — it is narrowly limited to functions that do not substantially alter input data or its semantics.

Conflating Article 13's deployer-facing instructions-for-use with Article 50's end-user-facing disclosures is a fourth mistake — Article 13 informs the professional deployer; Article 50 informs the natural person who encounters the system.

Open questions

  • Whether the Digital Omnibus extended the Article 50(2) marking deadline to 2 December 2026 for pre-existing systems. A secondary source claims this, but it was not confirmed against primary text on this research pass.
  • Whether Article 13 was genuinely unamended by the Omnibus, given the absence of a disclaimer on its Service Desk page — not independently verified.
  • What the Commission's 20 July 2026 Article 50 implementation guidelines substantively recommend, beyond the fact of their publication — the guidelines document itself was not fetched on this pass.

Frequently asked

FAQ
Did the Digital Omnibus extend the Article 50(2) machine-readable marking deadline for AI systems already on the market before 2 August 2026?
A secondary source makes this claim, but it was not confirmed against primary text on this research pass and should be verified before relying on it.
FAQ
Was Article 13 itself amended by the Digital Omnibus, or does its Service Desk page simply lack a disclaimer that other provisions carry?
Not independently verified.
FAQ
What do the Commission's 20 July 2026 Article 50 implementation guidelines actually recommend for practical labelling and disclosure?
Not yet reviewed by AGNUS; the guidelines document itself was not fetched on this pass.

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