What are the Article 50 transparency obligations?
The Article 50 transparency obligations are the EU AI Act’s disclosure layer, applicable from 2 August 2026. They fall into four duties: (1) people interacting with an AI system must be informed, unless this is obvious from the context; (2) AI-generated or manipulated audio, image, video and text must be marked in a machine-readable format; (3) deepfakes, meaning content resembling real persons, places or events, must be visibly disclosed; and (4) persons exposed to emotion recognition or biometric categorisation must be notified. Unlike the high-risk regime, these duties were not postponed by the omnibus package: the August 2026 date stands.
Who they hit in practice
- Customer-facing chatbots, voice agents and AI companions: interaction disclosure;
- Image, video and text generation features: machine-readable marking, for example Content Credentials (C2PA) or AI watermarking;
- Avatar, face and voice tools: visible deepfake labels;
- Turkey-based products serving EU users: the Act’s extraterritorial scope applies.
The legal dimension
Article 50 splits responsibility along the value chain: providers owe the machine-readable marking, while deployers owe the visible deepfake disclosure and the notification duties. The duties are cumulative, so a watermarked file without a visible label still breaches the deepfake rule, and disclosure must reach the person at the moment of exposure rather than sit in a terms page nobody opens.
Turkish context
Türkiye has no equivalent statute in force; KVKK and general provisions govern the same conduct domestically. That does not shrink the exposure for Turkish companies: a startup in Istanbul whose chatbot or generation feature reaches EU users falls within Article 50’s scope regardless of where it is incorporated. Compliance here is product work. Disclosure copy, provenance metadata and visible labels are engineering deliverables, not policies, so the realistic path is to put marking and labelling into the sprint plan rather than the legal binder.
Do: map each of the four duties to a concrete surface in your product and assign an owner to each. Don’t: assume the omnibus postponements bought you time here; they did not touch Article 50.
Related guides: The EU AI Act Was Postponed, AI Act Readiness Checklist.
Sources. Regulation (EU) 2024/1689 (AI Act).