- Art. 50 introduces four transparency duties: chatbots disclose they are AI; synthetic content is labelled; deepfakes are clearly revealed; emotion-recognition systems inform the people they concern.
- The information duty applies from 2 Aug 2026; technical machine marking (watermarking) — 2 Dec 2026 to verify.
- This is not a lawyer’s problem — it is a UI, metadata and publishing-process problem. It can be closed in 7 days.
What you have → what you must do: four duties in one table
| What you have | What Art. 50 requires | What it looks like in practice |
|---|---|---|
| Customer chatbot / voicebot | Clear information that the interlocutor is dealing with AI — unless obvious from context. | Message in the first reply or a permanent chat chrome element. Voicebot: announcement at the start of the call. |
| Images, video, audio from generators published externally | Labelling that content is AI-generated or manipulated — in a machine-readable format. | Label at publication + file metadata. Full technical watermarking from Dec 2026. |
| Realistic likenesses of people, places, events (deepfake) | Clear, visible disclosure that the content was artificially generated or manipulated. | Visible annotation on the content itself, not only in the caption. |
| Emotion recognition / biometric categorisation | Informing the persons the system acts upon. | Rare for SMEs — but if you use e.g. conversation sentiment analysis, the duty is yours. |
The fifth case everyone asks about: AI-generated text. Disclosure applies to text published to inform the public on matters of public interest — unless the content underwent human review and editorial responsibility sits with a named person or entity. For typical content marketing that means: human editing and a byline are your exception. But the graphic next to the text has no such exception.
What it looks like in the interface
For a chatbot the whole change is often one line — here is a variant that meets the rule without killing conversion:
Two design principles we use in deployments: disclose at the start of the interaction, not in the terms (the rule is about informing the person the system interacts with — a footer link does not do that) and neutral language instead of apologetic — conversion research does not forgive “warning, this is only a bot”.
Questions that come up in every workshop
LinkedIn post written with AI help — label it?
A company post you edited and stand behind with your name — as a rule, text disclosure does not apply (human control + editorial responsibility). But a generated graphic in the same post — must be labelled as synthetic. The most common mistake we see: firms police the copy and publish generator images with no trail.
What about content published before 2 August?
Priority goes to active touchpoints and new publications. Rational order: chatbot → publication templates → new content → only then any archive review. Do not burn resources retro-labelling everything retro scope — to verify.
Internal assistant for employees?
Art. 50 targets interactions with persons and public content. Internal tools sit under AI policy and GDPR — but hygiene is the same: staff should know they are talking to AI and what they may paste into it.
Sales email written by GPT?
Commercial correspondence is not “informing on matters of public interest” — the text duty does not cover that case. Voluntary transparency can still be a trust advantage, not a cost — we write about that regularly.
This is not a lawyer’s problem
A lawyer will tell you that you must label. They will not tell you where in the UI to place disclosure without killing conversion, which metadata to stamp on a generator file, or how to rebuild the publishing process so labels happen by default, not by memory. Art. 50 sits exactly at the junction of law, UX and engineering — which is why so many firms stall between legal and marketing, neither of whom feels ownership.
Deployment in 7 days
- Days 1–2 — touchpoint inventory. Every place AI meets a human or an audience: chatbots, voicebots, image/video generators, content templates, mail automations.
- Day 3 — decisions per channel. For each point: in scope?, disclosure formula, UI placement, who implements.
- Days 4–5 — implement. Chatbot message, labels and metadata in the publishing flow, template updates.
- Day 6 — policy and people. Add labelling rules to the AI policy + 30-minute training for content and support (also a building block for Art. 4 — yesterday’s article).
- Day 7 — evidence. Short note: what was inventoried, what was deployed, when, who owns it. Your material when the question comes — from an authority or a client.
We can run this plan for you
Review of all AI–customer touchpoints, decisions per channel, ready disclosure formulas (PL/EN), implementation guidance for the team, and an evidence memo. One review, fixed price, before 2 August.
Book a 30-minute callCompliance checklist: Art. 4 + Art. 50 before 2 August
12 control points with date and owner fields — including a per-channel labelling section.
Download checklist (PDF)Common questions
From when exactly does Art. 50 apply?
Information and labelling duties — from 2 August 2026. Technical machine-marking requirements (watermarking) — from 2 December 2026, after Digital Omnibus changes.
Is “AI-generated” in the post description enough?
For deepfakes — no: disclosure must be clear and visible on the content. For ordinary synthetic content, a publication label + metadata is a sensible minimum.
Who is liable — us or the tool vendor?
Duties split between the system provider (technical marking) and the deploying entity (disclosure to recipients). If you publish — you own disclosure on your side.
This article is informational and is not legal advice. Duty scopes are based on Art. 50 of Regulation 2024/1689 and the Digital Omnibus package status as of July 2026.