Article 50 is targeted, not universal
Article 50 includes transparency duties for particular situations, including AI systems designed to interact directly with natural persons, emotion recognition or biometric categorisation, deepfakes and certain AI-generated public-interest text. It does not mean that every use of AI in a workflow creates the same disclosure obligation.
Direct interaction has a specific meaning
The Commission explains that Article 50(1) focuses on systems designed for genuine two-way exchange. Merely collecting data or returning an automated response does not necessarily meet every criterion. A meeting bot that speaks or interacts may therefore raise different questions from a post-meeting analysis tool.
Good transparency goes beyond minimum scope
- Tell users when analysis is AI-assisted.
- Explain limitations and the role of human review.
- Do not present an extracted item as confirmed organizational truth before review.
- Keep evidence accessible so a person can verify important claims.
Official sources
Use the authoritative texts below when making legal or compliance decisions.
This resource provides general product and operational information. It is not legal advice. Your organization remains responsible for assessing its specific use, lawful basis and obligations.