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Article 50 for AI Startups

Last updated: 8 November 2026

Article 50 for AI startups usually means provider duties: shipping an AI system under your own name, even on third-party models, likely makes you its provider. Providers must design systems so people know they face an AI, and mark generated output machine-readably. The free Article50.io scan loads one public page in a real browser and shows the most severe finding.

The provider role is defined in Article 3(3). Which Article 50 duties apply depends on what your product does, not on being an "AI company".

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Does Article 50 apply to you?

It's likely relevant if you…

✔Ship a chatbot, voice agent or assistant that people interact with directly
✔Ship a product that generates images, audio, video or text
✔Put an AI system into service under your own name — including one built on a third-party model
✔Serve users in the EU, even if you're based outside it

It's probably not relevant if…

—Your AI neither interacts with people nor generates content — for example pure analytics, scoring or forecasting. That's outside the Article 50 obligations covered here, though other parts of the AI Act may apply
—You're still in research, testing or development and haven't placed the system on the market or put it into service (testing in real-world conditions isn't excluded)

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

Which parts of Article 50 apply, and why

Provider or deployer — Art. 3(3) / 3(4)

A provider develops an AI system (or has one developed) and places it on the market or puts it into service under its own name. Building your product on someone else's model doesn't change that — the AI system you ship is yours.

Art. 50(1) and 50(2) are provider duties

Design your system so people know they're interacting with an AI (50(1)), and mark generated output in a machine-readable, detectable way (50(2)). Systems on the market before August 2, 2026 have until December 2, 2026 for 50(2) (Art. 111(4)).

Scope reaches outside the EU

Non-EU providers placing AI systems on the EU market, or whose output is used in the EU, can be in scope under Art. 2(1)(a) and (c). Outside the EU? →

The most common gap: generative output with no marking

For generative AI startups, the gap that's easiest to miss is Article 50(2). A visible "made with AI" badge in your UI helps users, but the obligation is machine-readable marking that travels with the output — embedded metadata, watermarks or similar — so the content stays detectable after it leaves your product. If your model vendor already marks outputs, check that your pipeline doesn't strip it.

See labeling AI-generated content under Article 50(2) and the content label template.

What the free scan checks

The free scan checks your public website — AI chat widgets without a disclosure, and AI-generated content markers without a visible label. It doesn't test your product's outputs or model pipeline, so 50(2) marking inside your product needs its own review.

Check your site automatically

Article50.io is an automated scanner for the Article 50 transparency rules of the EU AI Act. It scans a website for potential Article 50 transparency gaps and generates a report of what the scan found and what it could not check, with remediation guidance, implementation instructions and disclosure wording you can paste in.

The free scan shows your single most severe finding. Scans are capped at 45 seconds — no signup, public pages only.