June 2026 · 6 min read

EU AI Act Article 50: the compliance checklist for SaaS (2026)

On August 2, 2026, the transparency obligations of the EU AI Act (Regulation 2024/1689, Article 50) become enforceable. They don't just affect OpenAI and Google: they apply to deployers — meaning any company that puts an AI system in front of people in the EU. If your SaaS has an AI support bot, a generative feature, or publishes AI-written content, this is your deadline.

1. Chatbot disclosure — Article 50(1)

Users must be informed they are interacting with an AI system, at the start of the interaction, in a clear and distinguishable way — unless it's already obvious from context. A small label inside your chat widget's first message is the practical pattern emerging from the draft Code of Practice on Transparency.

2. Machine-readable marking of AI output — Article 50(2)

If your product generates text, images, audio or video, the output must be marked as artificially generated in a machine-readable format and be detectable as such. The December 2025 / March 2026 draft Codes of Practice are explicit that no single technique is enough — expect to combine metadata, provenance manifests (C2PA-style) and, where feasible, watermarking.

3. AI-generated public text — Article 50(4)

AI-generated text published to inform the public must be disclosed as AI-generated, with an exception when a human exercised editorial control and responsibility. If your content pipeline is AI-first with light review, plan for disclosure.

4. Deepfakes — Article 50(4)

Realistic AI-generated or manipulated images, audio or video of real people, places or events must be visibly labelled. This catches more products than founders expect: avatar generators, voice cloning, photo-realistic scene generation.

5. Emotion recognition & biometric categorisation — Article 50(3)

If you analyse emotions or categorise people from biometric data, you must inform the people exposed. Sentiment-from-voice in call tools is the classic SaaS case.

The part nobody tells you: proof

Obligations are one thing; demonstrating compliance is another. When a national authority — or an enterprise customer's procurement team — asks, you'll want timestamped records showing which disclosure was shown, where, since when. Build the audit trail now, not after the first inquiry.

Your 10-minute starting point

Take the free Article 50 checker to see which of these five obligations apply to your product, then join the DiscloseKit waitlist — one script tag for the banner, the labels and the audit trail.

This article is general information, not legal advice. Primary sources: Regulation (EU) 2024/1689 Art. 50; draft Code of Practice on Transparency (March 2026).