Obligations
Transparency obligations under Article 50
Article 50 is not a single duty but four — with different obligated parties and exceptions. A practical breakdown for providers and deployers.
Updated 3 July 2026 · Reference material, not legal advice
Some AI systems are not high-risk but still carry transparency obligations under Article 50, so that people know when they are interacting with AI or viewing generated content. It is a common mistake to treat this as one obligation; in fact it splits into four distinct duties, each with a different obligated party and its own exceptions. All apply from 2 August 2026.
1. AI interaction disclosure — provider
Systems intended to interact directly with people must be designed so that users are informed they are dealing with an AI system — unless that is obvious from the context. Exception: systems authorised by law to detect or investigate criminal offences.
2. Synthetic-content marking — provider
Providers of systems that generate synthetic audio, image, video or text (including general-purpose AI systems) must mark the output in a machine-readable format, detectable as artificially generated, using solutions that are effective, interoperable, robust and reliable as far as technically feasible. Exception: assistive editing that does not substantially alter the input.
3. Emotion recognition and biometric categorisation notice — deployer
Deployers must inform people exposed to an emotion-recognition or biometric-categorisation system of its operation, and process personal data in line with the GDPR. Exception: lawfully authorised use for detecting criminal offences, with safeguards.
4. Deepfake and generated-text disclosure — deployer
Deployers must disclose that an image, audio or video is an artificially generated or manipulated deep fake. For text published to inform the public on matters of public interest, deployers must disclose that it was artificially generated — unless the content underwent human review and someone holds editorial responsibility. Exceptions also cover law-enforcement use and evidently artistic or satirical works.
Why the split matters
Because the obligated party differs, your role determines which duties are yours: duties 1 and 2 fall on providers; duties 3 and 4 fall on deployers. A system that both generates and is deployed may trigger obligations on both sides. Getting this wrong means either missing a duty you owe or spending effort on one that is not yours.
What this means in practice
Euridium treats Article 50 as four separately scoped obligations rather than one, routing each to the right party and surfacing its specific triggers and exceptions in the assessment — so the transparency duties you see are the ones that actually apply to you.
Run a guided assessment and get the obligations that apply to your role.
This guide is a plain-language summary for orientation. The authoritative text is Regulation (EU) 2024/1689 as published in the Official Journal of the European Union (12 July 2024). It does not constitute legal advice.