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How to check a website for EU AI Act Article 50

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To check a website for EU AI Act Article 50 (Regulation (EU) 2024/1689), confirm that any AI chatbot tells visitors it is an AI at the first interaction, that AI-generated deepfakes and public-interest text are labelled, and that AI outputs are machine-marked — then note what no automated scan can see. Article 50 has applied since 2 August 2026. General information, not legal advice.

Key facts

  • Art. 50(1): AI systems that interact with people must tell them it is an AI, unless obvious.
  • Art. 50(2): providers of generative AI must machine-mark outputs. A transition to 2 December 2026 covers only systems placed on the market before 2 August 2026.
  • Art. 50(4): deployers must disclose deepfakes and AI-generated text published to inform the public on matters of public interest.
  • Art. 50(5): the information must be clear and distinguishable, at the latest at the first interaction or exposure.
  • Art. 50(3) (emotion recognition and biometric categorisation) is rarely visible from a public website.
  • Fines: up to €15 million or 3% of worldwide annual turnover, whichever is higher (the lower of the two for SMEs), under Art. 99(4)(g) and 99(6). What happens if you ignore Article 50.

Step 1: List your AI features and your role

Start by writing down every place AI touches your visitors: chat or support widgets, voice agents, avatars, AI-generated images, video or audio, and AI-written articles. For each one, note who built it and whether you are the provider (you develop it or put it on the market under your name) or the deployer (you use a vendor's system). The role decides which Article 50 duties are yours: 50(1) and 50(2) are provider duties, and 50(3) and 50(4) are deployer duties.

Step 2: Do a 2-minute manual check

The fastest check is to look at your chat widget the way a first-time visitor does.

  1. Open the page in a private window, so you see it as a new visitor.
  2. Open the chat and read the first message. Does it say plainly that this is an AI?
  3. Ask "Am I talking to a person?" and read the reply.
  4. Take a dated screenshot of the greeting and the reply.
  5. Repeat on a phone — a separate mobile layout can hide or move the chat.

Check that the disclosure is accessible too (guidelines ¶142): it should be real text rather than an image, with enough contrast, and screen readers should announce it.

The Commission's guidelines (C(2026) 5054 final, non-binding) say first-turn greetings "may be combined, as appropriate, with persistent badges or labels visible throughout the interaction" (¶37).

Key point: the disclosure has to be where the visitor chats, by the first message. More detail: does my chatbot need an AI disclosure?

Step 3: Run an automated scan

Automated tools work in three different ways, and the method decides what they can see.

  • Rendered-browser scanners load the page with scripts running, so chat widgets appear as visitors see them. Examples: Article50.io, DisclosureProof, GotAlt.
  • HTML-only scanners read the page source. EUAiShield says it "does not execute JavaScript", so it may miss widgets that load by script.
  • Questionnaires base their result on your answers about your setup rather than the live page. Examples: Disclo's free Scope Check and the Commission's EU AI Act Compliance Checker (beta), which doesn't scan your page.

Article50.io loads your page in a real Chromium browser, reads text inside chat-like frames among the first 25 frames on the page, and reads C2PA and IPTC AI markers in up to 8 images. Your own output's 50(2) marking is marked as declared by you and not checked by the scan. Method in full: how the scan works.

For a side-by-side of free tools, see the best free Article 50 scanner and Article 50 scanners compared.

Step 4: Test the conversation itself

Open the chat, ask whether you are talking to a person or an AI, and keep the transcript, because a page scan only reads what a widget shows as it first loads. Tools such as AnswerTested can record this. Repeat the test whenever your vendor or prompts change. If you run an AI voice agent, call it as a customer would and check that it says it is an AI at the start of the call; no page scan hears a call.

Step 5: Check labels and machine-marking

Article 50(2) and 50(4) cover AI-generated content rather than chat: machine-marking (50(2)) is the provider's duty, and visible labels for deepfakes and public-interest AI text (50(4)) are the deployer's.

  • Art. 50(2) is a provider question. If you use a vendor's generative AI, ask the vendor how its output is machine-marked. The 2 December 2026 date is a transition for legacy systems only, not a general Article 50 deadline (Article 50 delay explained).
  • Art. 50(4) is about visible labels. If you publish deepfakes, or AI-generated text to inform the public on matters of public interest, label it. That includes AI-generated deepfakes from suppliers or stock libraries. Templates: AI content label, deepfake disclosure, AI chatbot disclaimer.

What a scan can't see

A scan can't see the following (full list on the method page):

  • Content behind a login, or that appears only after a click, a consent banner or opening the chat.
  • A mobile layout that differs from the desktop page.
  • What a voice agent says during a call.
  • Whether the AI output you produce is machine-marked (Art. 50(2)).
  • Custom chatbots from unrecognised vendors, and disclosure wording in other languages or unusual phrasing.
  • Other pages, image-only disclosures, how text in cross-site frames is presented, some image markers, video/audio, and legal questions such as your role or whether a disclosure is sufficient.
Key point: use a scan to find gaps quickly, then cover the rest by hand: logged-in areas, mobile, voice, other pages and your vendor's 50(2) marking.

Keep evidence of what you checked

Keep a dated screenshot of each chat greeting, dated transcripts from conversation tests, and the dated scan report. Each paid report from 30 Oct 2026 has a report ID, and its PDF has a SHA-256 fingerprint, so anyone you share it with can check the file is unaltered since it was issued (how the scan works). It says nothing about whether your site is compliant.

Common mistakes

Most failed checks come from checking too little, too late, or in the wrong view.

  • Checking only while logged in. Agent or admin views can hide the visitor greeting.
  • Treating a clean scan as clearance. It covers what the scan could see on one page, on one day.
  • Waiting for 2 December. That date is the Art. 50(2) legacy transition only; Art. 50(1) has applied since 2 August 2026.

Sources

Frequently Asked Questions

How do I check if my website complies with EU AI Act Article 50?

List your AI features and your role, check the chat greeting by hand in a private window and on a phone, run an automated scan of the live page, test a real conversation, and confirm deepfakes and public-interest AI text are labelled. Then cover what no scan sees. This is not legal advice.

What can an Article 50 scan not see?

Article50.io's scan checks one public page in a real browser. It cannot see content behind a login, a click, a consent banner or an opened chat, a separate mobile layout, voice calls, other pages, or whether your AI output is machine-marked. It cannot judge legal sufficiency or your provider or deployer role.

Is a clean scan a compliance guarantee?

No. A clean result means the scan found no obvious Article 50 issue in what it could check on one page, on the day it ran. It is not a compliance clearance or legal advice. Check what the report says it could not see, and cover those areas by hand or with a lawyer.

How do I test my website chatbot for an AI disclosure?

Open the site in a private window, open the chat, and read the first message: it should say plainly that this is an AI. Then ask "Am I talking to a person?" and check the reply. Keep a dated screenshot or transcript, and repeat the test after vendor or prompt changes.

Does a footer or terms notice count?

Usually not on its own. Article 50(5) requires clear, distinguishable information at the latest at the first interaction, and the Commission's guidelines (¶38) say a notice only in terms and conditions is insufficient on its own, as is a general line like "Services on this website use AI". Put the disclosure in the chat.

When does Article 50 apply — is 2 December the deadline?

Article 50 has applied since 2 August 2026. The 2 December 2026 date is only a transition for Article 50(2) machine-marking by generative AI systems placed on the market before 2 August 2026. It does not delay chatbot disclosure under Article 50(1) or deepfake and text labels under Article 50(4).

Do I need to check 50(2) watermarking myself?

Article 50(2) machine-marking is a duty of the provider of the generative AI system. If you use a vendor's AI, ask the vendor how its outputs are marked and keep the answer. A website scan cannot confirm it: in Article50.io's report, your own output's 50(2) status is marked as declared by you and not checked by the scan.

Is a free scanner enough?

A free scanner is a good first check, but it shows limited results and sees only what loads on one public page. You still need a conversation test, a check of other pages and mobile, and your vendor's answer on 50(2). Compare free tools in our guide to the best free Article 50 scanner.

Check your site automatically

The free Article50.io scan shows your single most severe finding — no signup, public pages only, and each scan is capped at 45 seconds. The €499 full report lists every finding with the Article it relates to, what the scan saw, suggested wording, and a coverage map of what it could not check. Scan for free · See a sample report

Related Article 50 resources

Automated technical guidance, not legal advice. Citations refer to Regulation (EU) 2024/1689.