The EU AI Act's Article 50 transparency obligations apply from August 2, 2026 — and unlike the high-risk documentation deadlines, this one was not extended by the Digital Omnibus. If your SaaS product has a chatbot, AI assistant, or generates AI content for EU users, you have a compliance obligation that is now weeks away.
This checklist covers every Article 50 requirement for SaaS products. Work through each item, identify your gaps, and you'll know exactly what needs to be done before August 2.
Article 50 applies regardless of risk classification. Your system does not need to be high-risk under Annex III for Article 50 to apply. A minimal-risk AI chatbot serving EU users is still subject to the disclosure requirement.
Part 1: Does Article 50 Apply to Your Product?
First, determine whether Article 50 applies at all. Answer these questions:
Does your product have a chatbot, AI assistant, or any AI system that has a direct text or voice conversation with users?
If yes → Article 50(1) applies. Users must be told they're interacting with AI.
Does your product generate AI images, video, audio, or text that is delivered to end users?
If yes → Article 50(2) likely applies. Generated content must be marked as AI-produced.
Do any EU residents use your product — as direct customers, or as end users of your B2B customers?
If yes → the regulation applies to those interactions regardless of where your company is based.
If you answered yes to any of the above, continue to Part 2. If no on all three, Article 50 likely does not apply to your current product — though you should re-evaluate when you add AI features.
Part 2: Article 50(1) — Chatbot Disclosure Checklist
These items cover the chatbot and AI-interaction disclosure requirement.
Your chatbot or AI assistant displays a disclosure at the start of every interaction
The disclosure must be shown before or at the beginning of the conversation — not after the user has already engaged. It must be clear that they are interacting with an AI system.
The disclosure is prominent — not buried in a tooltip, footer, or terms of service
A disclosure buried in a corner or only accessible via a help menu is unlikely to satisfy the "inform users" standard. It needs to be visible without any user action.
The disclosure uses plain language a non-technical user would understand
Legal jargon does not satisfy the intent of Article 50(1). "This conversation is powered by artificial intelligence" is better than "This interface uses an LLM."
If your AI can be mistaken for a human, the disclosure is unambiguous
The "obvious from context" exception in Article 50(1) is narrow. If your chatbot has a human name, uses first-person language, or appears in a context where users might assume they are talking to a human, you cannot rely on the exception.
The disclosure applies across all surfaces — web, mobile app, embedded widget, API integrations
If third parties embed your chatbot via API, you need to ensure disclosure is implemented at the integration level, or your terms require integrators to implement it themselves.
Part 3: Article 50(2) — AI Content Marking Checklist
These items cover the synthetic content watermarking requirement for AI-generated images, video, audio, and text.
AI-generated images served to users carry a visible label or watermark
A visible "AI-generated" label on the image or in its caption satisfies the human-readable component of the requirement.
AI-generated video and audio include audible or visible disclosure
For video, a persistent watermark or opening title card. For audio, an audible disclosure at the start of the content. Check EU AI Office technical standard guidance as it develops.
You have implemented or are implementing machine-readable metadata for AI-generated content
The EU AI Office is still developing technical standards. Reasonable current practice: implement C2PA content credentials where your toolchain supports it, and EXIF metadata for images. Document what you have done and your plan to comply with final technical standards when published.
Your content marking applies to deepfakes and synthetic media specifically
Article 50(4) specifically requires prominent disclosure for AI-generated content that depicts real persons, events, or places in a way that could mislead. This applies even if your general content marking implementation is not yet complete.
Part 4: Governance Documentation Checklist
Technical implementation alone is not enough. You need a documented governance record that demonstrates how and when compliance was achieved.
You have a written record identifying which systems in your product are subject to Article 50
List each AI system or feature, specify whether it's subject to Art. 50(1), 50(2), or both, and note the legal basis for your determination.
You have documented what disclosure mechanism you implemented, by whom, and when
If an authority investigates, the question will be: "Show us your compliance record." A screenshot of your UI is not the same as a dated governance document.
A named person in your organisation is responsible for Article 50 compliance
This does not need to be a dedicated compliance officer. At a startup, the CTO or founder can own this. But someone needs to be named, and the governance record should reflect that.
Your governance record includes a process for updating compliance as your product evolves
If you add new AI features, update the chatbot, or change how content is generated, your governance record needs to be updated. Document who is responsible for triggering that review.
Your governance record has been reviewed by qualified legal counsel
Not legally required, but strongly advisable. A 1–2 hour legal review of a pre-drafted governance record is inexpensive insurance against a €15 million fine exposure.
Scoring Your Checklist
| Result | What it means | Action |
|---|
| All items checked | You are likely compliant with Article 50 as of August 2, 2026 | Retain your governance record for audit purposes. Review when product changes. |
| UI disclosure done, no governance record | Half compliant — the visible layer is there, the paper trail is not | Generate a formal compliance record now. It takes under 30 minutes. |
| No UI disclosure, no governance record | Non-compliant. Deadline is August 2, 2026. | Implement disclosure and generate governance record immediately. |
| Unsure on most items | You need to audit your product before August 2 | Start with the product audit, then implement disclosure and documentation. |
The Gap Most SaaS Teams Miss
The most common failure mode for SaaS companies approaching Article 50 is implementing the UI disclosure but generating no governance documentation. The disclosure badge satisfies the user-facing obligation. But if a regulator investigates — triggered by a user complaint, a competitor, or a sector audit — they will ask for your documented compliance record, not a screenshot of your product.
A governance record shows:
- That you knew Article 50 applied to your system
- That you implemented compliance before the deadline
- Who is responsible for maintaining it
- How it will be updated as the system and the law evolve
Without that record, you are relying on your UI to tell the regulatory story. With it, you have a documented paper trail that demonstrates intentional, structured compliance — which is what regulators actually want to see.
Deadline: August 2, 2026
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