EU AI Act Article 50 Readiness Checklist

Map the systems and roles

• List interactive AI and generative systems that reach users or the public.
• Record whether the organisation is acting as provider, deployer or both for each use.
• Identify the EU market, users and content flows that could bring a use into scope.

Check the transparency trigger

• Identify where people interact directly with an AI system.
• Identify generated or manipulated image, audio, video and text that is published or shown externally.
• Flag deepfakes, emotion-recognition or biometric-categorisation uses for specific review.

Design the notice or marking

• Make notices visible at the point where they are useful rather than burying them in general terms.
• For provider-side generated-content marking, document how machine-readable marking is produced and tested where required.
• For deployer disclosures, define the wording, placement and exceptions that apply to the actual use case.

Assign ownership and evidence

• Name the person or role responsible for each transparency control.
• Keep records of scope decisions, system versions, notices, labelling and tests.
• Create an escalation route for uncertain cases and for systems whose behaviour or use changes.

Recheck after launch

• Test whether users can actually see and understand the disclosure.
• Monitor vendor and model changes that could alter provider/deployer responsibilities.
• Review the implementation against current Commission guidance and any sector-specific obligations.

Evidence behind this checklist

• European Commission, AI Office · Guidelines on transparency obligations for providers and deployers of AI systems · 2026-07-20 · Primary source
• European Commission, AI Office · Quick Facts: Transparency rules for AI systems · 2026-07-20 · Primary source

How evidence is selected and checked