AI rules · EU AI Act · Transparency

EU AI Act Article 50: Does Your Chatbot or AI Feature Need a Disclosure?

If your app has a chatbot, an AI assistant or generates text, images or audio, the EU AI Act now has something to say about it. Article 50 is short, and most products can meet it with a few lines of copy and code.

SafeLaunch Research 6 min read

The short answer

Yes, if people in the EU use it. Since 2 August 2026, Article 50 of the EU AI Act requires that people are told they are interacting with an AI system unless it is obvious, that AI-generated content is marked in a machine-readable way, and that deepfakes are disclosed. Generative systems already on the market have until 2 December 2026 for the marking duty.

Key takeaways

  • Article 50(1): chatbots and AI assistants must tell people they are interacting with AI, at the latest at the first interaction, unless it is obvious.
  • Article 50(2): providers of generative AI must mark audio, image, video and text output as AI-generated in a machine-readable way. Systems already on the market have until 2 December 2026.
  • Article 50(4): deepfakes, and AI-generated text published to inform the public, must be disclosed.
  • Fines for breaching Article 50 reach €15 million or 3% of worldwide annual turnover, whichever is higher.
  • California, South Korea, China and Texas have their own AI disclosure rules. SafeLaunch checks all of them in one scan.
On this page
  1. 1. Does the EU AI Act apply to my app?
  2. 2. When does Article 50 apply?
  3. 3. How do I disclose a chatbot under Article 50(1)?
  4. 4. How do I mark AI-generated content under Article 50(2)?
  5. 5. Do other countries require AI disclosure?
  6. 6. How SafeLaunch checks AI features

01

Does the EU AI Act apply to my app?

The AI Act applies to providers (who build an AI system or put it on the market under their name) and deployers (who use an AI system in their product or business). It reaches companies outside the EU when their AI system is used in the EU or its output is used there.

Most apps built with AI builders are deployers: they call a model from OpenAI, Anthropic, Google or another provider and show the result to users. Article 50 puts duties on both roles, so a startup wrapping a model in a chatbot still has to make sure users know they are talking to AI.

Which Article 50 duty applies to which product
Your productArticleDuty
Support chatbot, AI assistant, AI agent that talks to users50(1)Tell people they are interacting with AI, unless obvious
Generates images, audio, video or text for users50(2)Mark output as AI-generated in a machine-readable way
Uses emotion recognition or biometric categorisation50(3)Inform the people exposed to it
Publishes deepfakes, or AI text on matters of public interest50(4)Disclose that the content is AI-generated or manipulated
Which Article 50 duty applies to which product

02

When does Article 50 apply?

EU AI Act dates that matter for websites and apps
DateWhat applies
2 Feb 2025Prohibited practices (Art. 5) and AI literacy for staff (Art. 4)
2 Aug 2025Duties for general-purpose AI model providers
2 Aug 2026Article 50 transparency duties
2 Dec 2026End of the grace period for machine-readable marking (Art. 50(2)) for systems already on the market
2 Dec 2027High-risk duties for Annex III uses (hiring, credit, education, essential services), as postponed by the Digital Omnibus
2 Aug 2028High-risk duties for AI in products covered by Annex I
EU AI Act dates that matter for websites and apps

03

How do I disclose a chatbot under Article 50(1)?

Article 50(5) says the information must be given in a clear and distinguishable manner, at the latest at the first interaction or exposure, and must meet accessibility requirements. In practice:

  • Label the chat window with words, not only an icon: "AI assistant" in the header.
  • Say it in the first message: "Hi, I'm an AI assistant. I can make mistakes. Ask for a person any time."
  • Don't give the bot a human name and photo without the AI label. A persona is allowed; pretending to be human is the problem.
  • Make the label readable by screen readers: real text with sufficient contrast, not text baked into an image.
  • Keep it on hand-offs: if a human takes over, say so, and if AI drafts replies a human sends, consider saying that too.
Prompt for your AI builder: add an Article 50 chatbot disclosure
Make this change without altering anything unrelated.

Our chat widget must tell users they are talking to an AI system before or at
the first message.
1. Add the visible text "AI assistant" to the chat header, next to the bot name.
2. Make the bot's first message start with: "Hi, I'm an AI assistant. I can make
   mistakes. Type 'human' to reach a person."
3. Use real text (not an image), at least 4.5:1 contrast, and give the chat
   region aria-label="AI assistant chat".

Done when:
- A new visitor sees "AI assistant" before sending a message.
- The first bot message states it is an AI.
- A screen reader announces the chat as an AI assistant.

04

How do I mark AI-generated content under Article 50(2)?

Article 50(2) applies to providers of AI systems that generate synthetic audio, image, video or text. The output must be marked in a machine-readable format and be detectable as AI-generated, as far as technically feasible. If you only display a third-party model's output, check what your model provider already embeds, and don't strip it.

  • Images and video: keep or add provenance metadata, such as C2PA Content Credentials, and don't remove metadata the model provider embeds.
  • Audio: use your provider's watermarking where offered.
  • Text: machine-readable marking of text is harder; record generation in your system and label AI text visibly where users could be misled.
  • Visible labels help everywhere: a small "Generated with AI" tag also covers deepfake disclosure under 50(4) and similar rules in other markets.

05

Do other countries require AI disclosure?

Yes. If you sell beyond the EU, these rules from the SafeLaunch rulebook may apply too:

AI disclosure rules outside the EU
MarketLawWhat it requires
CaliforniaBOT Act (B&P §17941)A bot used to sell something or influence a vote says it is a bot
CaliforniaSB 243 (from 1 Jan 2026)Companion chatbots tell users they are talking to AI, have a self-harm protocol, and give known minors break reminders at least every 3 hours
CaliforniaAI Transparency Act, SB 942 (operative 2 Aug 2026)Generative AI providers with over 1 million monthly users offer a free detection tool and embed disclosures
South KoreaAI Basic Act (from 22 Jan 2026)Tell users in advance that a service uses generative or high-impact AI; label AI-generated outputs
ChinaAI Content Labelling Measures (from 1 Sept 2025)Explicit and implicit (metadata) labels on AI-generated text, images, audio and video
TexasTRAIGA, HB 149 (from 1 Jan 2026)Prohibited AI uses; health care providers tell patients when AI is used in their care
ColoradoSB 26-189 (from 1 Jan 2027)Tell consumers when automated decision-making influences consequential decisions; explain adverse decisions
AI disclosure rules outside the EU

06

How SafeLaunch checks AI features

  • Finds AI features in your pages and code, such as chat widgets and calls to AI model APIs.
  • Checks for a disclosure a user would see before or at the first interaction.
  • Reviews AI claims in your marketing for misleading statements under consumer law, such as the FTC Act §5 in the US.
  • Applies each market's rule you select and cites the article, then writes the fix and a prompt for your builder.
  • Adds an AI use policy to the Launch Fix compliance pack, which also supports the AI literacy duty in Article 4.

Run a free scan to see whether your AI features are flagged, or read how findings become fix prompts.

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FAQ

Frequently asked questions.

Under Article 50(1) of the EU AI Act, yes, if people in the EU use it and it isn't obvious they are talking to AI. The information must be clear and given at the latest at the first interaction. This has applied since 2 August 2026.

Up to €15 million or 3% of total worldwide annual turnover, whichever is higher, under Article 99. For SMEs and startups, the lower of the two amounts applies.

Usually a deployer of the model, but you can become a provider of an AI system if you put a system on the market under your own name. Either way, Article 50 puts transparency duties on you: deployers must disclose deepfakes and public-interest AI text, and the chatbot disclosure duty sits with the provider of the system people interact with.

The high-risk deadlines were moved by the Digital Omnibus, to 2 December 2027 for Annex III uses and 2 August 2028 for Annex I. The Article 50 transparency duties were not postponed; only systems already on the market got until 2 December 2026 for machine-readable marking.

No. It is general information based on the SafeLaunch rulebook and the text of Regulation (EU) 2024/1689. For your specific case, ask a qualified lawyer.

Sources and further reading

This article is general information, not legal advice. SafeLaunch is automated software, not a law firm; a report records what was checked on one version and is not a certificate of compliance. Read the disclaimer.

From the founder

SafeLaunch is built by Raghav R Handa, a lawyer-turned-builder in New Delhi. He writes about this topic in plain English:

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