On 8 May 2026, the European Commission published draft guidelines on the transparency obligations under Article 50 of Regulation (EU) 2024/1689, the EU AI Act. A public consultation on the draft closed on 3 June 2026. The guidelines are non-binding until adopted in final form. The Commission is expected to adopt final transparency guidelines before 2 August 2026, the date on which the Article 50 obligations become applicable across the EU.
Article 50 of the EU AI Act imposes four transparency obligations. Article 50(1) requires providers of AI systems that interact with natural persons to notify users they communicate with an AI, unless this is obvious from context. Article 50(2) requires providers of AI systems generating synthetic audio, image, video, or text to mark that output as AI-generated. Article 50(3) requires deployers of emotion recognition and biometric categorisation systems to notify persons within range. Article 50(4) requires deployers of deepfake content to disclose its AI-generated or AI-manipulated nature. An exception in Article 50(4) applies to evidently artistic, creative, satirical, or fictional content; disclosure is still required in those cases but must not hamper display or enjoyment of the work.
Providers of conversational AI products deployed in the EU must implement user-facing notifications before the Article 50(1) obligation becomes applicable on 2 August 2026. AI content generators, including marketing technology vendors producing synthetic images or video, must embed machine-readable labelling or provenance data in output to satisfy Article 50(2). Deepfake deployers, including advertisers using AI-generated likenesses, must disclose the AI-manipulated nature of content even where the depicted person is fictional and no deception is intended.
The draft guidelines confirm that the Article 50(1) chatbot notification obligation does not apply where the AI nature is obvious from context. The exception for artistic and creative deepfakes under Article 50(4) is narrowly drawn: the creative character must be evident to the ordinary viewer. National competent authorities retain discretion to assess adequacy of disclosure methods, and the final guidelines may refine the standards for machine-readable labelling under Article 50(2).
Licentium advises technology companies, advertisers, and content platforms on EU AI Act transparency compliance. If your products generate or deploy synthetic content or operate conversational AI in the EU, we can assist with compliance gap analysis and disclosure implementation. Work we undertake includes EU AI Act Article 50 compliance mapping, synthetic content labelling strategy, deepfake regulatory analysis, and public consultation submissions.