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Which parts of Article 50 actually reach your system?

Article 50 has five paragraphs. They put different duties on providers and on deployers, and only one of them carries a deadline that is still ahead rather than behind. Eight questions is usually enough to tell them apart.

Transition window

82days until 2 December 2026

2 Aug 20262 December 2026

Counted on 2026-09-11, Europe/Brussels. Systems generating synthetic content, already on the EU market before 2 August 2026, have to carry machine-readable marking.

The part most guidance still gets wrong

Four of the five paragraphs in Article 50 had no transition at all. They applied from 2 August 2026. Only the machine-readable marking duty in 50(2), and only for systems already on the market before that date, runs to December.

A great deal of published material describes the December date as though it covered the whole of Article 50, or as though it were the high-risk regime. It is neither. The questions below separate them.

Read this before the questions

MetaMinds is not a law firm and does not provide legal services in any jurisdiction. This page performs an engineering triage, not a compliance determination. It cannot see your system, your contracts or your market, and its output is a list of things worth checking with your own counsel.

  1. 01Which are you, for this system?

    Article 50 puts different duties on the provider and the deployer, and the same organization is often both for different systems. The provider develops it or puts it on the market under its own name or trademark. The deployer uses it under its own authority.

  2. 02Is the system placed on the market, put into service, or is its output used, in the European Union?

    The Act reaches non-EU organizations. If people in the EU use the system, or the output produced by it is used in the EU, it is generally in scope regardless of where you are established.

  3. 03Does the system interact directly with people?

    A chat assistant, a voice agent, an automated caller. The question is whether a person is on the other side of an exchange with it.

  4. 04Does it generate or manipulate audio, image, video or text output?

    Synthetic content of any kind, including text. A retrieval system that composes an answer generates text. Note the third option: Article 50(2) does not reach systems that only assist with standard editing or do not substantially alter what the user gave them.

  5. 05When was this system first placed on the EU market or put into service?

    This is the question that decides whether the December 2026 transition applies to you, and it is the one most often answered from memory. Release notes, changelogs and press announcements settle it better than recollection.

  6. 06Does it perform emotion recognition or biometric categorisation?

    Inferring emotional state, or sorting people into categories from biometric data. This is a deployer duty and it is easy to miss in a product that does it as one feature among many.

  7. 07Does the system generate or manipulate image, audio or video that resembles real people, places or events, and would falsely appear authentic?

    This question is about image, audio and video only, because that is the limb of Article 50(4) it maps to. Text is handled by the next question. Examples: synthetic voice of a named individual, a generated image of a real place, a video of someone who did not say the thing.

  8. 08Is generated text published to inform the public on matters of public interest?

    News, current affairs, public health, elections. If it is, whether a human holds editorial responsibility for the published output changes the answer, which is why both parts are asked together.

0 of 8 answered

What this tool does not do

  • It does not tell you whether you are compliant. It tells you which paragraphs are worth reading closely.
  • It does not cover the rest of the Act. Prohibited practices under Article 5, the high-risk regime and the GPAI obligations are separate questions with separate dates.
  • It assumes you are not law enforcement. Article 50 carries carve-outs, across several of its paragraphs, for AI systems authorised by law to detect, prevent, investigate or prosecute criminal offences, subject to safeguards for the rights of third parties. If that describes your deployment, the answers above are not written for you and the carve-outs are worth reading in the text itself.
  • It does not store your answers, set a cookie, or ask for an email address. The result lives in your own URL and nowhere else.
  • It does not replace counsel, and the two places it is most likely to be too coarse are the obviousness carve-out in 50(1) and what counts as editorial responsibility in 50(4).

The full timeline, including which deadlines the July 2026 Digital Omnibus moved and which it did not, is on our Article 50 page.