Article 50 EU AI Act: Basics free of charge, implementation in your systems
What Article 50 requires since 2 August 2026 is publicly accessible – no one should have to pay for that. We provide you with guidelines, assessment frameworks, and AI register templates free of charge. What is paid for is what cannot be derived from this: the analysis of your specific website, your shop, your Odoo environment, and your assistants – and the implementation in exactly these systems.
Request practice package free of charge Book initial consultation
Or first the self-assessment in six questions
From bloopark – official Odoo partner focused on the DACH SME sector. Technical and procedural implementation in your systems, no legal advice.
Voluntary label: This image was generated with AI. We apply what we implement on this page.
First: Who bears which obligation?
The AI Act distinguishes two roles. Almost every misjudgment in practice begins with confusing these two.
Provider – in the English text "provider"
Whoever develops or has developed an AI system and brings it to market or puts it into operation under their own name or brand (Article 3 number 3). In most companies, these are the manufacturers of the tools used – not you. Attention: an assistant operating under your own brand can place you in the provider role.
Operator – in the English text "deployer"
Whoever uses an AI system professionally under their own responsibility (Article 3 number 4). That is you, as soon as your marketing, your editorial team, your shop, or your service uses AI. The English term is "deployer", not "user" – the obligations for published content are tied to this role.
What applies from 2 August 2026
Article 50 of the EU AI Act regulates transparency, not prohibitions. Six points are relevant for companies that use AI in marketing, websites, shops, or customer communication.
Article 50 paragraph 1 · Provider
Recognisable AI interaction
Systems that interact directly with people must make it clear that they are AI. The obligation is directed at the providers of the system. In the case of an assistant operating under your own brand, this role may also apply to your company.
Article 50 paragraph 2 · Provider
Machine-readable marking
Providers of generative AI systems must mark their outputs in a machine-readable way. For providers of AI systems that generate synthetic audio, image, video, or text content and were brought to market before 2 August 2026, Article 111 paragraph 4 sets a deadline until 2 December 2026, to fulfil Article 50 paragraph 2. As an operator, you do not bear this obligation – but you do have a practical interest in not losing existing source data in your systems.
Article 50 paragraph 3 · Operator
Emotion recognition and biometric categorisation
Anyone using a system for emotion recognition or biometric categorisation must inform the individuals affected about the operation of the system and process personal data in accordance with GDPR. The key factor is the reference to biometric data. Mood analysis on texts or a simple tonal assessment in the service tool does not automatically fall under this; whether a voice agent is captured depends on whether it evaluates the voice as a biometric feature. This must be examined on a case-by-case basis.
Article 50 paragraph 4 · Operator
Image, audio and video
Anyone publishing AI-generated or AI-edited image, audio or video content that could appear genuine must disclose this. This obligation applies to the operators, namely your company or agency. An intention to deceive is not required for this.
Article 50 paragraph 4 · Operator
AI texts: narrower scope than often assumed
The disclosure obligation for AI-generated texts applies to publications that inform the public about matters of public interest. It does not apply when there is substantive human review with clear editorial responsibility. Normal product texts and newsletters generally do not fall under this.
Article 50 paragraph 5 · Form
Clear, distinguishable and accessible
The information must be clear and distinguishable at the latest by the time of the first interaction or exposure – and the applicable accessibility requirements comply. The article does not mention any regulations itself; for companies within the scope of the Accessibility Strengthening Act, these requirements arise from the BFSG. This is the point that is almost always forgotten in implementation.
Even if Article 50 does not concern you: AI competence
Article 4 has been in effect since 2 February 2025 and applies to providers and operators. It requires measures that promote the development of AI competence of their own staff and those acting on their behalf – scaled according to prior knowledge and context of use.
Important for classification: Article 4 paragraph 1 explicitly states that the provision does not oblige providers or operators to guarantee a specific level of AI competence for any person, and Article 4 is not listed in the penalty catalogue of Article 99. Article 50, on the other hand, is explicitly included there. Thus, Article 4 is not a training obligation with a certification requirement, but an obligation that practically reaches every operator – even the one who, after the check, finds: there is nothing to label in our content.
Article 4 is a separate obligation, not a by-product of labelling. What it specifically requires depends on prior knowledge and context of use and must be assessed separately. An internal guideline and a documented briefing are common components for this – they do not replace this assessment.
Who is affected by which obligation?
- Article 50: only for affected content or systems
- Article 4: for every professional AI use
- Both obligations apply independently of each other
What this means in practice
Not every AI-generated asset requires the same labelling. The following classification follows the wording of Article 50 and the guidelines of the EU Commission from July 2026. The final legal assessment in individual cases remains reserved for your legal advice.
Photorealistic AI images in marketing and website
What matters is not photorealism, but the deepfake definition: The content must noticeably resemble real people, objects, places, or events and be perceived as real. Whether purely synthetic but credible representations are also included is a matter of interpretation – the Commission's examples suggest this direction, the wording does not decide it.
Product photo with AI-generated background
A real product in an AI-generated environment is generally not subject to disclosure according to the Commission's examples, as long as the product itself is not altered or misleadingly presented. If the product itself is enhanced, the assessment changes.
Abstract and recognisably unrealistic motifs
Illustrations, fantasy scenes, and motifs that are recognisably not real are generally outside the definition according to the guidelines. Also, common image editing such as colour correction or cropping does not fall under this.
Product texts, category texts, newsletters
For purely commercial content, the text obligation generally does not apply. It may look different when statements are made regarding health, safety, environment and sustainability, or finances. A documented editorial approval process is the most effective lever here.
Chatbots, assistants and voice agents
Customers should recognise at the latest during the first contact that they are speaking with an AI system. A note that is only in the imprint or in the terms and conditions is usually not sufficient.
Advertising and campaign motifs
The exemption for recognisably artistic, satirical or fictional works is to be interpreted narrowly according to the guidelines and usually does not apply to predominantly commercial content.
Self-assessment in six questions
The same logic we use in the review – condensed into six questions. The classification on the right is a first professional tendency, not a legal assessment of your individual case.
Individual case examination
1. Do you publish images, videos or audio content that are wholly or partially generated by AI?
Then it must be checked whether the content falls under the deepfake definition of Article 50 paragraph 4: noticeable similarity to real persons, objects, places or events and the impression of being real. Photorealism alone does not determine this.
Probably not affected
2. Do you only change the background or environment in real product photos without altering the product itself?
According to the examples from the Commission, this is usually uncritical. The crucial factor is product fidelity, not the synthetic origin of the background.
Probably not affected
3. Do you exclusively use abstract or recognisably unrealistic AI motifs?
Such motifs are generally outside the definition according to the guidelines. A brief documentation of this classification remains sensible.
Action required likely
4. Is there a chatbot, assistant or voice agent running on your website, in the shop or in telephony?
Then it is about recognisability at first contact – and the question of whether you slip into the provider role through your own branding.
Individual case examination
5. Does one of your systems evaluate emotions based on biometric data or categorise individuals based on such data?
Then it must be checked whether the evaluation is actually based on biometric data – only then does Article 50 paragraph 3 apply as an operator obligation, along with the data protection requirements. Text-based sentiment analysis is generally not.
Discretionary question
6. Are AI texts being generated with statements about health, safety, sustainability or finance – without documented editorial approval?
Here, the subject matter decides, not the channel. A named approval step transforms the uncertainty into a clear exception.
Answered more than one question with yes? Then the review framework is worthwhile – and a 45-minute conversation.
What you should check now
These ten points form the review framework that we work with in the AI transparency check. It is deliberately practical and ultimately provides a list that you can prioritise and work through.
Request review framework as PDF
Ten points on two pages, without sales text.
AI inventory
Which tools today generate or modify customer-facing content – in marketing, editorial, shop, support and sales?
Image stock
Which assets are AI-generated or AI-edited, how photorealistic are they, and is this documented anywhere?
Website and Shop
Where do these contents specifically appear: product images, category images, backgrounds, banners, landing pages, blog, social preview images?
Assistants and Automation
Is there a noticeable indication at first contact – in the chat widget, in the voice agent, in automated email responses?
Editorial Approval Process
Who reviews AI texts in terms of content, with what expertise, and who bears the documented editorial responsibility?
Labeling Logic
How and where is it labeled? A maintainable system is crucial instead of manual individual cases that will be lost in the next release.
Accessibility of the Notice
Is the transparency notice also perceivable for screen readers and when using keyboard navigation? Article 50 paragraph 5 requires compliance with applicable accessibility requirements.
Metadata and Origin
Do embedded origin information from the provider remain intact during upload, image conversion, and in the CDN, or are they removed?
Roles, Policy and Traceability
Is there an internal policy, and can it be traced for each asset which tool it was created with, when, and who approved it?
Agencies and Suppliers
Is it regulated what agencies, photographers, and content service providers must disclose about AI components in delivered content?
Free of Charge
Practical Package Article 50
Basic knowledge of Article 50 is publicly available. We do not charge for this. We have prepared it for practical use – so that you can assess your starting position before you even speak to us.
- Practical Guide Article 50, 12 pages – the five paragraphs in plain text, provider and operator obligations separated, six practical cases with justification, both cut-off dates, sanctions framework realistically classified.
- Review Framework Checklist – ten review points as a worksheet to fill out, plus self-assessment in six questions with evaluation.
- AI Register Template as an Excel file – tools, types of content, role, classification, labelling status and review dates all in one place, with evaluation.
This will get you quite far without us. You only pay for what cannot be derived from general material: the classification of your specific systems and the implementation. About the packages
This information serves as professional guidance and does not constitute legal advice.
Request package
You will receive the three files directly afterwards for download. No sales call, no subscription.
Prefer to talk first? Book a 45-minute initial consultation – also free of charge.
How great is the risk realistically?
The circulating millions are upper limits and the least likely scenario for SMEs. A sober classification into three levels is more useful.
The legal framework
Article 99 paragraph 4 states that for violations of Article 50, fines of up to 15 million euros or 3 percent of global annual turnover apply – depending on which amount is higher. This is a maximum limit, not a standard penalty, and the national implementation is up to the member states.
What actually applies to SMEs
For small and medium-sized enterprises including start-ups, Article 99 paragraph 6 reverses the rule: the lower of the two values applies. Anyone who unfiltered transfers the “15 million or 3 percent” to SMEs is calculating with the wrong number.
The more likely scenario
In the German market, pressure typically comes first from the side: a competition law warning from competitors or associations, triggered by a publicly visible website. This is quicker, cheaper to initiate, and targets exactly the content at issue here. Whether a specific case is suitable is a legal question – reducing vulnerability is a technical one.
How bloopark supports
We explain the legal situation free of charge. Our work then begins: on your actual systems, processes, content, and your Odoo environment – first clarity about the inventory, then a viable labelling, then a process that will still hold for the next release and the next campaign.
Review and Inventory
We look at your systems, not a general model: which AI tools are actually in use and what customer-side content they generate – across website, shop, Odoo, newsletters, and assistants.
Technical Classification and Gap Analysis
We separate for your specific inventory what is affected by Article 50, what is not, and what has discretion – finding by finding, as a prioritised basis for your legal assessment, not as a substitute for it.
Implementation in Odoo and Website
We implement rather than recommend: labelling on images and content, transparency notice in the chatbot or voice agent, adjustment of snippets, product data, and shop templates in Odoo and website – maintainable rather than hand-crafted, and perceivable without barriers.
Process and Evidence
Approval and documentation steps in Odoo, integrated into your existing processes rather than placed alongside: clear roles, internal policy, and an evidential situation that also holds up in an audit or supplier questionnaire. Ongoing support available upon request.
This is what the result looks like
You will receive an audit report – no certificate and no seal. This is intentional.
- Checked scope, audit date, and applied criteria are named in the document
- For each finding: affected, not affected, or discretion – with justification
- Prioritised gap list as a basis for legal assessment
- Contains the note: this is not a certification by an accredited body
The AI transparency check
The basic material is free. You pay for the work on your systems – in three steps: you check yourself, we check for you, we implement it.
No subscription, no licence fee. The two paid packages are one-off project services: you commission once and receive a result.
Step 1 · You check yourself
Practical package Article 50 free of charge
0 €
The material with which you assess your starting position yourself – without conversation, without invoice.
For all who want to know first whether they are affected at all.
- Practical guide, 12 pages, on the five paragraphs of Article 50
- Assessment framework with ten points as a checklist
- Excel template for your AI register
- Self-assessment in six questions
Step 2 · We check for you
Basic check
290 € one-off, plus VAT.
We look at what is happening with you and tell you in writing what is missing. Assessment and recommendation, still without implementation.
For small shops, websites and solo self-employed individuals who want clarity quickly.
- Personal check of your website, your shop and your Odoo environment against Article 50
- Written findings with the specific gaps
- Clear recommendation on what to do
- A follow-up call, 30 minutes
Step 3 · We implement it
Complete check + implementation recommended
€2,400 one-off, plus VAT.
We check and implement the transparency obligations directly in your systems afterwards – effective, not just as a document.
For medium-sized companies with multiple systems or ongoing AI use.
- Everything from the basic check
- Implementation of transparency obligations: labelling, AI register, provider and user notices
- Setup in Odoo and on your website
- Two follow-up calls
- Email support for 30 days
After that: ongoing review, if you wish
New tools, new campaigns, new releases: labelling rarely comes out on the first day, but at the fourth update. Upon request, we will check periodically – optional, separately commissioned, not part of the three packages.
Larger system landscapes
Multiple brands, shops, PIM, CRM and assistants – with approval and documentation process in Odoo. We will agree on scope and price individually.
All prices are net plus statutory VAT, each one-off. Fixed prices for one domain (website including shop) and one Odoo system.
€290 one-off, plus VAT.
Commission basic check
You do not need an appointment for this. You send us the key data, we confirm the scope and start date by email.
- You submit the form. Two minutes, no preliminary questions.
- We confirm within one working day scope and start date by email and invoice the €290, payable by bank transfer.
- Findings and 30-minute call usually within two weeks after approval.
Would you prefer to speak first? Book initial consultation – 45 minutes, free of charge.
Your details
By submitting, you place an order. A contract is only formed with our order confirmation by email.
This is how the check proceeds
Practice package and initial consultation, free of charge
First, the free materials: guide, review framework, AI register template. If you wish to proceed afterwards, a 45-minute conversation in which we assess your AI use and determine which level is appropriate. No preparation required on your part.
Review
We will look at your website, your shop, your Odoo environment, your assistants, as well as your image and text inventory and record the tools actually used.
Classification
You will receive a clear distinction: affected, not affected, discretionary scope – each with justification and priority.
Implementation
Labelling, notes, processes and documentation are integrated into your existing Odoo and website structure – fitted into existing workflows, not as a parallel procedure alongside.
Operation
Optional and separately commissioned: We will regularly check when new tools, campaigns or releases are added.
Frequently Asked Questions
The questions that existing customers most frequently ask us about Article 50.
No. The disclosure obligation is not solely tied to the origin of an image, but to its effect: relevant are contents that could appear real. Abstract or recognisably unrealistic motifs generally do not fall under the guidelines of the EU Commission. However, photorealism alone does not establish the obligation: what matters is whether the content noticeably resembles real people, objects, places or events and can be perceived as real. This very distinction is what we make in the review.
This obligation is directed at the providers of generative AI systems, not at you as the operator. For providers of AI systems that generate synthetic audio, image, video or text content and were placed on the market before 2 August 2026, Article 111 paragraph 4 sets a deadline of 2 December 2026 to comply with Article 50 paragraph 2. Practically relevant for you is mainly that your own systems do not remove existing origin information unnoticed.
Article 50 paragraph 5 requires clear and distinguishable information at the latest by the time of the first interaction or exposure, and this information must comply with the applicable accessibility requirements. A notice that only appears in documents outside of the actual use generally does not meet this.
Article 4 addresses providers and operators of AI systems and has been in effect since 2 February 2025. It requires measures that promote the development of AI competence among staff, scaled according to prior knowledge and context of use. Article 4 paragraph 1 explicitly clarifies that the regulation does not obligate providers or operators to guarantee a specific level of AI competence for any person; Article 4 is not listed in the penalty catalogue of Article 99. Article 50 is explicitly included there. Article 4 is an independent obligation and applies regardless of whether content needs to be labelled.
No. We work on the technical and procedural side: inventory, assessment framework, implementation, documentation. The result is a technical classification with a prioritised gap list as a basis for the legal assessment – not as a substitute for it. The legal assessment of your individual case remains reserved for your legal counsel.
The basic check concludes with the assessment of your specific environment: You will receive a written report detailing the specific gaps, a recommendation on what to do, and a follow-up call lasting 30 minutes – but nothing will be changed in your systems. The check and implementation include the work on: We will actually integrate the labelling into up to five page and snippet types as well as the transparency notice for an assistant into the website, shop, and Odoo – as maintainable logic that will still apply after the next release. Those who wish to implement from the outset can directly book the full check – the basic check is included.
The foundational materials – practical guide, audit framework checklist, and AI register template – are free of charge. The basic check costs €290, the full check with implementation costs €2,400 – each a one-time fee, net plus VAT. No subscription, no licensing fee. Both are fixed prices for one domain (website including shop) and one Odoo system. You are not paying for the explanation of the legal situation, but for the analysis of your actually deployed systems and the implementation. The full check already includes the basic check – you do not pay for the assessment twice. Multiple brands, shops, or systems as well as the optional ongoing audit will be calculated additionally.
The basic check usually runs within two weeks from approval. The implementation depends on the scope and release cycle of your website and will be coordinated in advance.
Article 99 paragraph 4 specifies fines of up to 15 million euros or 3 percent of global annual turnover for violations of Article 50, depending on which amount is higher. For small and medium-sized enterprises including start-ups, the lower value applies according to Article 99 paragraph 6. These are maximum limits and not standard penalties; the national implementation is up to the member states. In the German market, a competition law warning from competitors or associations is typically closer than a fine procedure.
Then the effort is low and the timing is good: Once AI content is distributed across multiple channels and systems, subsequent labelling becomes significantly more expensive than a one-time clean structure. And Article 4 on AI competence will reach you even if there is nothing to label in your content.
Everything that is generally applicable is free: the practical guide to Article 50, the assessment framework checklist with ten points, the self-assessment in six questions, and the AI register template. This material is available as a practical package for download; an initial conversation is not necessary for this. Payment is only required for what cannot be derived from this: the analysis of your specific website, your shop, your Odoo environment, and your assistants, the gaps derived from this, and the technical as well as procedural implementation in your systems.
Legal bases for further reading
All statements on this page can be verified at the source. These are the versions we refer to.
- Regulation (EU) 2024/1689 (EU AI Act), consolidated version of 27 July 2026 – EUR-Lex
- Article 50 in the wording – AI Act Service Desk of the European Commission
- Guidelines of the EU Commission on transparency obligations (July 2026)
- FAQ of the EU Commission on Article 50 – including the deadline 2 December 2026
- Regulation (EU) 2026/1744 (Digital Omnibus on AI) – amendments to Articles 4, 99 and 111
Where does your AI use stand today?
Start for free: Guide, assessment framework and AI register template are sufficient to assess your starting position. If you want to know what this means for your specific systems afterwards, we can discuss it for 45 minutes.
Request practice package free of charge Book initial consultation
Legal notice: The contents of this page are for professional orientation and do not constitute legal advice. They are based on the consolidated version of Regulation (EU) 2024/1689 of 27 July 2026, the amendments by Regulation (EU) 2026/1744, the guidelines of the European Commission on Article 50 from July 2026 and the voluntary Code of Practice on Transparency of AI-generated Content. Interpretation issues are partially open; the binding interpretation is the responsibility of the courts. Please have your individual case legally examined. Status: 16 September 2026.