While the EU AI Act’s Annex III high-risk deadline moved to December 2027, one obligation did not move: Article 50 AI content disclosure. From 2 August 2026, any organisation that uses AI to generate content that interacts with or is served to individuals in the EU must disclose this fact. That includes AI-powered chatbots, AI-written marketing content, AI-generated customer service responses, and AI-created images or videos. If your business does any of this — and in 2026 almost every business does — you need a disclosure policy, a labelling framework, and trained staff. Here is what Article 50 actually requires and how to comply before August.
What Exactly Does Article 50 Require?
Article 50(1) requires that any AI system interacting with individuals — including chatbots and virtual assistants — must clearly disclose that the person is interacting with an AI, not a human. Article 50(2) requires that AI-generated content, including synthetic images, audio, and video, must be technically marked or watermarked to indicate its AI origin. Article 50(1) applies from 2 August 2026. Article 50(2) was delayed by the Omnibus to 2 December 2026. Both obligations apply to any organisation serving EU customers, regardless of where the organisation is based.
Which Businesses Are in Scope?
Any organisation that uses AI chatbots on their website, uses AI to write or assist with customer-facing content, uses generative AI tools in their marketing or communications team, or deploys AI-generated images or videos in advertising — and serves any customers in the EU — is in scope. This includes UK companies post-Brexit. Being based outside the EU does not exempt you if you are serving EU individuals. Most UK businesses with any EU customer base will be caught by Article 50(1) from August 2026.
Your Pre-August Compliance Checklist
Audit every AI tool your organisation uses that produces customer-facing content or interactions. 2. Identify which tools involve AI interactions with EU individuals — chatbots, virtual assistants, AI-written emails or articles. 3. Draft an AI content disclosure policy covering what must be disclosed, when, and how. 4. Update your website, chatbot interfaces, and customer communications to include appropriate disclosures. 5. Train your marketing, content, and customer service teams on the new requirements. Wishory’s Article 50 Transparency Assessment delivers a complete disclosure framework in 5 days. From £1,500. Book at wishory.com/book.