Article 50: Transparency Rules for Chatbots, Deepfakes, and AI Content

Three Key Transparency Rules

Article 50 sets out transparency requirements that apply to certain types of AI regardless of their risk classification. This means even if your AI tool isn't high-risk, these rules might still apply to you. The three main scenarios are: AI systems that interact directly with people, AI systems that generate synthetic content, and AI systems that perform emotion recognition or biometric categorization.

These requirements are about basic honesty. People deserve to know when they're talking to a machine, when the content they're viewing was created by AI, and when their emotions or biometric characteristics are being analyzed.

Chatbots and Interactive AI

If you deploy a chatbot on your website or use an AI system that interacts with customers, you must clearly inform people that they're dealing with an AI system. The notification should happen before or at the start of the interaction — not buried somewhere in your terms of service.

A simple, visible message like "You are chatting with an AI assistant" at the beginning of the conversation is sufficient. The goal is to make sure people can make informed decisions about how they interact with the system and what information they share.

AI-Generated Content

If your business creates or distributes content generated by AI — whether it's text, images, audio, or video — you must disclose that it was artificially generated or manipulated. This is particularly important for content that could be mistaken for real events or real people (deepfakes).

The disclosure should be machine-readable where technically possible, meaning there should be metadata or watermarking that indicates the content is AI-generated. For content shared publicly, a visible label or disclaimer is also needed.

Practical Implementation

Review all the places where your business uses AI to interact with people or create content. For each one, make sure there's a clear disclosure mechanism in place. Update your website, apps, and customer communications to include appropriate labels. Train your staff to be upfront about AI use in their interactions with customers. Keep records of where AI is used and how you disclose it — this documentation is your compliance evidence.

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements change frequently — verify current rules with official sources. Built by Sawai Gyoseishoshi Office, Hiroshima, Japan.