DAILY

Transparency obligations

Available Artificial intelligence

Art. 50 AI Act requires transparency for certain AI systems regardless of their risk class. Providers must make interaction and synthetic content recognisable; deployers must disclose emotion recognition, biometric categorisation, deepfakes and AI-generated text on matters of public interest. The obligations apply since 2 August 2026.

Role

One organisation can be both provider and deployer of the same system.

1. Do you develop the AI system, or have it developed, and place it on the market or put it into service under your name (provider)?
Art. 3 Nr. 3 KI-VO Open in the law texts
2. Do you use the AI system under your authority in the course of a professional activity (deployer)?
Art. 3 Nr. 4 KI-VO Open in the law texts
3. Was the system placed on the market or put into service before 2 August 2026?

For such systems the marking duty for synthetic content applies only from 2 December 2026.

Verordnung (EU) 2026/1744 KI-VO

Provider obligations

4. Is the system intended to interact directly with natural persons (chatbot, voice assistant, phone bot)?
Art. 50 Abs. 1 KI-VO Open in the law texts
5. Is it obvious to a reasonably well-informed, observant and circumspect person, from the circumstances, that they are interacting with an AI system?

Only then is the notice not required. If in doubt, answer no.

Art. 50 Abs. 1 KI-VO Open in the law texts
6. Does the system generate synthetic audio, image, video or text content, including as a general-purpose AI system?
Art. 50 Abs. 2 KI-VO Open in the law texts
7. Does the system only perform an assistive function for standard editing, or does it not substantially alter the input data or its semantics?

Examples: spell checking, cropping, colour correction. Then no marking is required.

Art. 50 Abs. 2 UAbs. 2 KI-VO Open in the law texts

Deployer obligations

8. Do you operate an emotion recognition or biometric categorisation system?

Emotion recognition in the workplace and in education is prohibited under Art. 5(1)(f), except for medical or safety reasons.

Art. 50 Abs. 3 KI-VO Open in the law texts
9. Do you generate or manipulate image, audio or video content that appreciably resembles real persons, objects, places or events and would falsely appear authentic (deepfake)?
Art. 50 Abs. 4 UAbs. 1 KI-VO Open in the law texts
10. Is the content evidently part of an artistic, creative, satirical, fictional or analogous work or programme?

Then a disclosure that does not hamper the display or enjoyment of the work is sufficient.

Art. 50 Abs. 4 UAbs. 1 KI-VO Open in the law texts
11. Do you publish AI-generated or manipulated text with the purpose of informing the public on matters of public interest?
Art. 50 Abs. 4 UAbs. 2 KI-VO Open in the law texts
12. Is the text subject to human review or editorial control, with a natural or legal person holding editorial responsibility?
Art. 50 Abs. 4 UAbs. 2 KI-VO Open in the law texts
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