EU AI Act Article 50 — Readiness Checklist
Transparency obligations apply from 2 August 2026 — the one AI Act deadline the Digital Omnibus did not postpone. Work through the 16 checks below. Every unticked box is a gap.
What changed, and what didn't. Postponed: Annex III high-risk obligations (to 2 December 2027) and Annex I embedded AI (to August 2028). Not postponed: Article 50 transparency — from 2 August 2026. Fines reach €15,000,000 or 3% of worldwide annual turnover, whichever is higher (Art. 99(4)).
A. Does Article 50 apply to you?
A single “yes” means the checks below concern you.
1. Do you run chatbots, voice bots or any conversational AI that interacts with people?
2. Do your tools generate synthetic audio, images, video or text (marketing visuals, product photos, reports)?
3. Do you publish AI-generated or AI-assisted text that informs the public on matters of public interest?
4. Do you create or distribute realistic AI content depicting real people, places or events (deepfakes)?
5. Do you operate emotion-recognition or biometric-categorisation systems?
6. Do you embed third-party generative AI (APIs, SaaS tools) in your products or workflows?
Most organisations answer “yes” at least twice without realising it — the marketing team’s image generator counts, and so does the support bot.
B. If you provide an AI system
C. If you deploy AI systems
D. Organisational readiness
Your score
- 16 / 16 — you are ahead of most of the market. Keep your evidence file current.
- 12–15 — close the gaps before 2 August. Most take days, not months.
- Under 12 — start with an inventory and a readiness review this week.
Free readiness review
We review one of your workflows — what survives an audit and what does not — and you leave with a written gap list. No cost, no obligation.
Request a free readiness review
Background on the harder half — making a marking independently verifiable, not just present: Article 50: mark AI output — and prove the marking is yours.
AI disclosure: this page was drafted with AI assistance and reviewed and published under named editorial responsibility — see our own Article 50 posture, where we publish our own score (5/16 at baseline). This checklist is general information, not legal advice. Regulatory dates reflect the Digital Omnibus political agreement of May 2026; until publication in the Official Journal the original texts formally apply. Your lawyer decides applicability.