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Article 50 EU AI Act: Self-Check in 10 Questions | FHC+P
Self-check · EU AI Act

Article 50 Self-Check

10 questions that show whether your AI content is labelling-safe

Since 2 August 2026 the transparency obligations of Article 50 apply: AI interaction and AI content must be recognisable, with exemptions for editorially reviewed content under human responsibility. Go through the 10 questions. Every "no" or "don't know" is a concrete work item. Orientation from implementation practice, not legal advice.

1 · Do you have an overview of where AI content is created in your company?

Marketing, sales, support, HR: AI texts and images are often created decentrally. Without an inventory there is no labelling strategy.

2 · Do your customers recognise when they are talking to a chatbot?

In AI interaction, people must be able to recognise that they are dealing with an AI, unless it is obvious. A clear notice in the chat window is usually enough.

3 · Are AI-generated images, audio, and video marked machine-readably?

Synthetic content must be marked as AI-generated in a machine-readable format (e.g. metadata/provenance standards). Check whether your tools deliver that.

4 · Is there an approval process before AI texts are published?

An exemption applies to published texts if a human has reviewed them and carries editorial responsibility. Exactly this requires a defined approval or veto process, not just lived practice.

5 · Can you prove the review if in doubt?

An approval log (who reviewed what and when) turns the exemption into solid proof, towards supervisors, customers, and in a dispute.

6 · Is it defined what happens if NOBODY reviews?

Fully automatically published AI content must be labelled. Your process should cover this case explicitly: automatic label instead of silent publication.

7 · Are deepfake risks addressed?

Whoever creates or distributes realistic image, audio, or video depictions of real persons or events must disclose their artificial origin. Also relevant for internal training or marketing purposes.

8 · Do your service providers and agencies know which rules apply at your company?

If external parties create content for you, they need your labelling and approval requirements, contractually and in practice.

9 · Are your employees trained (Article 4)?

AI literacy has been mandatory since February 2025. For Article 50 this concretely means: everyone who creates or approves AI content knows the labelling rules and their own process.

10 · Is all of this documented and current?

A lean AI policy that names tools, processes, and owners, and grows with new use cases. One document that is lived beats ten binders of theory.

Evaluation

More than two nos?

Then a structured pass is worth it: AI inventory, risk classification, and implementing the missing items, usually done within a few weeks. We implemented Article 50 productively in our own platform Personativ (approval and veto principle, automatic labelling, proof log) and bring this hands-on experience into your organisation. All services at a glance: Implementing the EU AI Act.

From self-check to implementation

A free intro call: we prioritise your open items and give an honest effort estimate.

Questions & Answers

FAQ

Have further questions? Feel free to contact us directly via our contact form or by e-mail.

Does all AI text have to be labelled? +

No. Published texts that a human has reviewed and for which someone carries editorial responsibility fall under an exemption. What matters is a defined approval process with proof. Fully automatically published content, however, must be labelled.

What does machine-readable marking of AI images mean? +

Synthetic images, audio, and video must be marked so that software can recognise the AI origin, for instance via metadata or provenance standards. Visible labels alone are not enough; the tool that creates the content must technically provide the marking.

Who is liable if an agency creates the content? +

The obligations apply to the actors along the chain, and as the client you carry responsibility towards your customers. Practically this means: labelling and approval requirements belong in the agency contract and in the shared working process. The legal assessment of individual cases is done by your law firm.