silamin

Applies 2 August 2026

Article 50 is the one that reaches almost everybody.

Not just high-risk deployers. If your website has a chatbot, or you publish AI-assisted content, Article 50 transparency duties apply to you from 2 August 2026 — a Sunday, so Monday 3 August in practice.

Most of what it asks for is a sentence in the right place. The work is knowing which sentence, where, and — just as usefully — what you are exempt from and can stop worrying about.

Book 25 min → Or just email me

Four duties, and you probably have one or two

Article 50 splits duties between the provider of an AI system and the deployer using it. Most SMEs are deployers of someone else's tool.

Art. 50(1) · Provider

People must know they're talking to AI

Anyone interacting with an AI system has to be told, at the latest at the first interaction, unless it is obvious. Clear and distinguishable — not a line in your terms of service.

Typical trigger: a support chatbot, a booking assistant, an AI phone agent.

Art. 50(2) · Provider

Synthetic output must be machine-readable

Providers of systems generating synthetic audio, image, video or text must mark the output so detection tools can identify it as AI-generated.

Grace period: systems already on the market before 2 August 2026 have until 2 December 2026 for this one — and only this one.

Art. 50(3) · Deployer

Emotion recognition and biometric categorisation

People exposed to these must be informed. ⚠ Screen against the Article 5 prohibitions first — some of these uses are not disclosable, they are banned outright.

Typical trigger: sentiment scoring on recorded calls, attention analytics.

Art. 50(4)–(5) · Deployer

Deepfakes, and published AI text

Deepfakes must be disclosed as artificially generated. AI-generated text published to inform the public on matters of public interest must be disclosed — or carry substantive human review and editorial responsibility.

Typical trigger: an AI-drafted blog or newsletter published without a named human editor.

Diagnostic Article 50

Small on purpose. A deadline this close is not the moment to sell you a three-week programme.

Entry point

Diagnostic Article 50

€900 · 48 hours
  • Inventory of your public AI surface. Every touchpoint a regulator or a customer can see — chat widgets, generated copy, synthetic media, embedded vendor AI.
  • Qualification, item by item. Which paragraph catches it — 50(1), (2), (3), (4) or (5) — or which exemption releases it.
  • The disclosure wording, written. In French and English, ready to paste, placed where it satisfies "clear and distinguishable" rather than buried.
  • A dated evidence note. One page for your file recording what was assessed, on what date, and on what basis. Compliance you cannot evidence is compliance you cannot rely on.
  • What you are NOT required to do. Assistive editing, purely artistic or fictional work, and content under real human editorial control are treated differently. Half the value here is a shorter list.

Delivered as a written report. One follow-up call included. No retainer, no lock-in.

Two things I would rather say up front

This is not legal advice

I am an engineer, not a lawyer. What I do is find every AI touchpoint you have, map it against the text of the Regulation, and write the disclosures. Where something is genuinely a legal judgement call, I will say so and tell you it needs a lawyer rather than guess in your file.

The deadline is real, the panic is not

Article 50 is a transparency duty, not a certification regime. There is no audit, no filing and no fee. For most SMEs the honest answer is a short list of sentences and a note in the file — and if that is your situation, the diagnostic will tell you so and end there.

Frequently asked

Was this delayed like the high-risk rules?
No. The Digital Omnibus agreed in June 2026 moved standalone Annex III high-risk obligations to 2 December 2027 and product-embedded ones to 2 August 2028. It did not move Article 50. The only relief is a four-month grace on the Article 50(2) machine-readable marking for systems already on the market, to 2 December 2026.
We only use vendor AI. Does it still apply?
Yes, as a deployer. Article 50(3), (4) and (5) are deployer duties and they do not care who built the tool. Your vendor's compliance is not automatically yours — and whether your contract with them covers it is one of the things worth checking.
What happens if we do nothing?
Nothing on Monday. There is no filing deadline to miss. It becomes a supervision question — in France, CNIL and DGCCRF — and the exposure is that you are non-compliant from that date onward rather than from the date someone notices.
Can you just tell me if I'm caught?
Often, yes, from your public site alone, and I am happy to do that in an email for free. Email me the URL. If the answer is "you're fine", that is the answer you get.

Send me your URL

I will tell you which of the four duties you are caught by, if any. That part is free and takes me ten minutes.

hello@silamin.dev Or book 25 minutes →