EU AI Act Article 50: the four transparency rules every SaaS must follow

Article 50(1) requires providers of AI systems that interact with natural persons to inform them they are interacting with AI, unless this is obvious from context. The disclosure must be clear, distinguishable, and provided at the latest at the time of the first interaction. Examples that satisfy: greeting message that names AI, persistent badge in chat header, splash screen on first widget open. Examples that do NOT satisfy: AI mention only in footer, disclosure only in terms of service, generic 'powered by' line.

Article 50(2) requires providers of AI systems generating synthetic audio, image, video, or text to mark the outputs as artificially generated in a machine-readable format. The expected standard is C2PA (Coalition for Content Provenance and Authenticity). European standardisation bodies are working on a harmonised standard. Until C2PA fully stabilises, regulators accept a combination of visible label plus metadata tag (HTML data attribute for text, EXIF for images, ID3 for audio).

Article 50(3) requires deployers of AI systems performing emotion recognition or biometric categorization to inform affected natural persons of the system's operation. The disclosure must be in advance and in a way the person can understand. This applies regardless of whether the inference is used to make decisions about the person. Note: workplace and educational emotion recognition is generally prohibited under Article 5(1)(g) - Article 50(3) covers the lawful contexts (e.g., medical, safety, public space).

Article 50(4) requires deployers of AI systems that generate or manipulate image, audio, or video content constituting deepfakes to disclose that the content has been artificially generated or manipulated. The disclosure must be clear and distinguishable. Exception: where the use is authorised by law, the disclosure must still be made unless that disclosure would defeat the lawful purpose. For commercial SaaS, deepfakes nearly always require disclosure - artistic uses, satire, and political speech all carry disclosure obligations.

Build Article 50 into your default UX, not as an afterthought. For chatbots: persistent header badge plus first-interaction message. For generative content tools: visible 'AI-generated' label plus HTML metadata or C2PA tag on every output. For emotion or biometric features: explicit on-screen disclosure before the inference runs, with affected-user acknowledgement. For deepfakes: synthetic-origin label on every output frame plus C2PA tag. Each implementation should be documented in your compliance archive: screenshot of the disclosure, code snippet of the metadata implementation, ToS section quoting Article 50, and date of deployment.