EU AI Act Article 50 Readiness Checklist 2026

EU AI Act Article 50 readiness checklist

A practical control-oriented review for teams operating interactive or generative AI. Article 50 transparency obligations apply from 2 August 2026. This page helps organize operational questions before legal review; it is not legal advice or a compliance certification.

FreeNo signupLocal-only checklist state

0 of 16 readiness checks complete

1. Scope & role

Inventory every customer-facing or content-generating AI feature.For each feature, document whether the organization is acting as provider, deployer, or both.Record whether EU users, EU customers, or EU-targeted output are involved.Identify any applicable exception or transition before treating a requirement as settled.

2. Direct AI interaction

For AI systems interacting directly with people, determine whether users are clearly informed that they are interacting with AI.Verify disclosure timing is no later than the first interaction or exposure where required.Check that disclosure is clear, distinguishable and accessible.Keep evidence of the deployed disclosure, owner and review date.

3. Synthetic-content marking

For systems generating synthetic audio, image, video or text, identify what machine-readable marking is produced.Test whether marks survive resizing, compression, export and other downstream processing.Document technical feasibility, interoperability, robustness and limitations.Record whether the pre-2-August-2026 transition for Article 50(2) may apply.

4. Deployer disclosures

Check for deepfake use and the required disclosure workflow.Check public-interest AI-generated text for disclosure duties and human editorial-review exceptions.Check any emotion-recognition or biometric-categorisation use for exposure notices and privacy obligations.Assign an accountable owner for incidents, changes and periodic re-review.

What to do with the gaps

Do not convert this into a box-ticking exercise. For every unresolved item, record: the affected AI use case, owner, evidence, decision, remediation, target date and next review. That turns a regulatory-readiness question into an operational control.

Official sources

The Commission states Article 50 applies from 2 August 2026, with a limited transition to 2 December 2026 for certain pre-existing systems only regarding the marking/detection obligation under Article 50(2). Applicability is fact-specific.