Direct AI interaction
Determine whether natural persons interact directly with the AI system and whether the applicable disclosure route is triggered or an exception may apply.
Article 50 creates transparency duties for several kinds of AI interaction and AI-generated or manipulated content. The operational question is not only whether a disclosure exists, but whether the organization can identify the applicable route, preserve the implementation evidence and revalidate it when the system changes.
The European Commission published guidance on Article 50 transparency obligations in July 2026. The relevant Article 50 obligations began applying on 2 August 2026.
Start with the actual system, role, use case and evidence boundary. The same regulation can produce different obligations for different actors and systems.
Determine whether natural persons interact directly with the AI system and whether the applicable disclosure route is triggered or an exception may apply.
For covered AI-generated or manipulated audio, image, video or text, preserve how machine-readable marking and detectability are implemented and tested where required.
Identify whether a deployment uses covered biometric categorisation or emotion-recognition functionality and preserve the affected-person notice pathway and any exception analysis.
For relevant deployer uses, preserve content classification, disclosure placement, editorial-control facts, publication chronology and exception reasoning.
The goal is not merely to reach an answer. It is to preserve what facts, evidence, scope and limitations supported that answer at that time.
Record the system, version, intended purpose, deployment context and whether the organization is acting as provider, deployer or another regulated actor.
Separate Article 50(1), 50(2), 50(3) and 50(4) questions instead of collapsing them into one generic transparency checkbox.
Preserve screenshots, marking architecture, detectability testing, notice wording, exception analysis, editorial-control facts and version history where relevant.
A model, interface, content pipeline, deployment or source-state change can make yesterday’s evidence insufficient even if the historical record remains true.
Choose the smallest operating tier that fits the portfolio today. Upgrade when system count, team size or governance scope actually requires it.
Keep a living system-level evidence record with obligations, gaps, versions and revalidation state.
START EVIDENCE PASSPORT →Coordinate evidence, owners, documentation, incidents and team compliance work in one governed workspace.
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START INSTITUTION →Use the free classifier to establish the system, intended purpose, possible actor role, EU exposure and unresolved facts. When continuing evidence infrastructure is needed, paid access begins at $19 per month. Independent human readiness review remains a separate service.
The Article 50 transparency obligations covered by the current Commission guidance began applying on 2 August 2026. Applicability still depends on the specific system, actor, use and relevant exceptions.
No. The correct analysis depends on the system, the interaction, the actor and the applicable exception or boundary. A generic chatbot label is not a substitute for a system-specific determination.
No. A disclosure can be one piece of evidence. The organization may still need to support applicability, timing, placement, wording, marking, detectability, exceptions and continuing validity.
No. TA-14 can structure classification, evidence, gaps, review and revalidation. Software access does not itself constitute legal advice, regulatory approval, conformity assessment or certification.
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