V77 Trust

Transparency duties: chatbots, generated content and deepfakes

When you must tell people they're dealing with AI, and when AI output must be marked.

2 min read·Updated 8 November 2026Product ownersMarketingEngineers

Article 50 sets transparency duties that apply whatever the risk tier.

What providers must do

  • AI that interacts with people must make it clear they're talking to AI, unless it's obvious. Has applied since 2 August 2026.
  • AI that generates audio, images, video or text must mark the output in a machine-readable way so it can be detected as AI-generated. This has applied since 2 August 2026; systems already on the market before that date have until 2 December 2026.

What deployers must do (since 2 August 2026)

  • If you use emotion recognition or biometric categorisation, tell the people exposed to it.
  • If you publish a deepfake (realistic image, audio or video of real people, places or events), disclose that it's AI-generated. Clearly artistic, satirical or fictional work only needs a light-touch disclosure.
  • If you publish AI-generated text on matters of public interest, disclose it, unless a person reviewed it and takes editorial responsibility.

How to do it well

  1. 1
    Tell people at the start of the interaction, not hidden in terms and conditions.
  2. 2
    Use plain words: "You're chatting with an AI assistant."
  3. 3
    For marking, use an established standard such as C2PA content credentials or watermarking your provider supports.
  4. 4
    Keep a record of how and where you disclose. That's your evidence.
Tip

The European Commission published guidelines and a voluntary code of practice on transparency for AI-generated content in summer 2026. They're a good reference for what "machine-readable" means in practice.

This page explains the law to help you find your way. It isn't legal advice.

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