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EU AI Act Article 50 Operations-Readiness Checklist

Use “yes,” “no,” or “unsure” to identify operational questions that need work or qualified legal review. This checklist does not decide whether Article 50 applies and does not establish compliance.

1. Territory and role

• Is the AI system offered, used, or producing outputs used in the European Union?
• Have you identified the legal entity responsible for each workflow?
• For each system, have you documented whether you built, commissioned, rebranded, or merely use it?
• Have you screened whether the organization may be a provider, deployer, or both?
• Are all “unsure” role or territorial conclusions routed to qualified counsel?

2. Direct AI interaction

• Does the system conduct a genuine two-way exchange directly with natural persons?
• Is the person clearly told they are interacting with AI no later than the first interaction?
• Does the notice use plain language instead of a vague phrase such as “automated experience”?
• Is the notice perceivable on mobile and by assistive technology?
• Have you retained a screenshot, system version, date, and owner for the notice?

3. Provider output marking

• Does an own-branded system generate synthetic text, image, audio, or video?
• Have engineering or the upstream vendor documented machine-readable marking and detectability?
• Have you recorded why any standard-editing exception is believed to apply?
• Are B2B or industrial exceptions treated as narrow and fact-specific?
• If relying on a transition, are placing-on-market dates documented and legally reviewed?

4. Deployer disclosures

• Do you publish AI-generated or manipulated media that may resemble an existing or plausibly existing person, object, place, entity, or event?
• Could the media falsely appear authentic or truthful to its foreseeable audience?
• If the content may be a deepfake, is the disclosure visible or audible at first exposure?
• Does the disclosure survive download or resharing where practicable?
• Are you avoiding reliance on hidden metadata alone for a perceivable disclosure?
• For creative, satirical, fictional, or artistic work, is the context-specific disclosure approach documented?

5. Public-interest text

• Is AI-generated or manipulated text published?
• Is its purpose to inform the public, and does it concern a matter of public interest?
• If no disclosure is used, was the substance deliberately reviewed by a person with relevant knowledge and professional judgment?
• Could that reviewer approve, alter, or reject the substance and fact-check sources?
• Is a natural or legal person holding final editorial responsibility?
• Is the review more than spelling, grammar, formatting, or a procedural approval?
• Have you retained the review, source, change, and approval record?

6. Disclosure quality and evidence

• Is every potentially applicable disclosure clear and distinguishable?
• Does it appear no later than first interaction or exposure where required?
• Have relevant accessibility requirements been considered?
• Are optional EU icons evaluated without treating their use as proof of compliance?
• Is each workflow assigned to a named operational owner?
• Do you retain system versions, source files, provider documents, disclosure screenshots, review logs, and publication dates?
• Is there a process to reassess workflows when systems, guidance, or content types change?

Official source set

Regulation (EU) 2024/1689, Article 50 text, European Commission Article 50 guidelines, and European Commission Article 50 FAQ. Re-check the official materials and legal advice because rules, guidance, standards, and enforcement practice can change.