For your business · Agencies

Article 50 for Agencies

If your agency builds chatbots or produces AI-generated content for clients, Article 50 disclosures have to end up where the public sees them — usually on the client's live site. Who is legally responsible for them isn't always clear-cut, so the safe move is to build the disclosure into the deliverable.

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Does Article 50 apply to you?

It's likely relevant if you…

✔Build or configure AI chatbots and assistants that go live on client sites
✔Produce realistic AI-generated images, video or voices for client campaigns
✔Write or auto-generate public-interest articles for client publications using AI
✔Run your own AI-powered tools or chat on your agency's site

It's probably not relevant if…

—You don't use AI in client deliverables or on your own site
—You use AI only for internal brainstorming and drafting, and what ships is human-made or not realistic enough to pass as authentic

Not sure which situation you're in? Start from does Article 50 apply to you?

Which parts of Article 50 apply, and why

Chatbots — Art. 50(1) and 3(3)

50(1) binds the provider. On the text of Art. 3(3), a client that has an AI system developed and puts it into service under its own name can be its provider — so a chatbot you build and launch under the client's brand may make the client the provider, not you.

Deep fakes — Art. 50(4) and 3(4)

50(4) binds the deployer: whoever uses the AI system under its authority. When an agency generates a deep fake on a client's instructions, whether that's the agency, the client or both isn't settled by the Act.

Marking — Art. 50(2)

Machine-readable marking is the duty of whoever provides the generation tool — usually the tool vendor. Your job is not to strip it when you edit, compress or export client assets.

The most common gap: the disclosure gets lost in handover

The typical failure isn't anyone deciding to skip a disclosure — it's that nobody owns it. The agency delivers a chatbot or a set of photorealistic AI visuals, the client's team publishes them, and the label that was in the brief never makes it onto the live page.

Ship the disclosure as part of the deliverable — the chat notice in the widget config, the caption with the image — and say in your contract or statement of work who places and maintains it. The free chatbot and deepfake templates are a starting point.

What we can't tell you about agency liability

The AI Act doesn't address agency–client relationships directly. Who counts as provider or deployer depends on the facts — whose name the system runs under, and under whose authority the AI is used — and we haven't found authoritative guidance that settles how that applies to agencies. We're not going to guess. If allocation of responsibility matters to a client engagement, that's a question for a lawyer and your contract.

What the free scan checks

Run the free scan on each client site before and after launch. It flags AI chat widgets without a disclosure and AI-generated content markers without a visible label on public pages — the gaps that most often slip through handover.

Check your site automatically

Article50.io is an automated Article 50 transparency assessment platform that scans websites for potential EU AI Act transparency obligations and provides remediation guidance, implementation instructions, and compliance-ready disclosure language.

The free scan shows your single most severe finding in about 30 seconds — no signup, public pages only.