What records prove I met the EU AI Act Article 50 disclosure duties?
Keep four records: the disclosure text or notice itself, where and when it was presented, the marking applied to AI-generated content where marking applies, and the work records showing which outputs the disclosure covered. Review the receipt and actual deliverable before accepting a handover.
Scope: a plain-language summary for record planning, not legal advice. Which Article 50 duties apply depends on your role and your content; advice for your situation governs.
Article 50 is the transparency part of the EU AI Act: people should know when they are interacting with an AI system, and certain AI-generated or manipulated content should be marked or disclosed, in the ways the article sets out for providers and deployers. Unlike the Annex III high-risk duties, whose application the Digital Omnibus moved to 2 December 2027, the Article 50 transparency duties begin in August 2026, which makes their records a current project rather than a future one.
The proving problem is familiar: a disclosure duty is met in moments, a banner shown, a notice given, a label attached, and moments evaporate. The records that survive are the disclosure artefact itself (the exact text or label as used), its placement record (where it appeared and from what date), and the link to the work it covered. Where the disclosure rides on a deliverable, the handover is the natural carrier: the job record shows the output, and the disclosure notice can be saved as part of the same record the client receives.
Keep the four records on the same retention discipline as your other delivery records, and review them when your surfaces change: a redesigned page, a new bot, a new content type each re-opens the question of where the disclosure lives now. The checklist below is written to be run surface by surface.
Checklist: Article 50 disclosure records, per surface
For each surface where people meet your AI: 1. The disclosure artefact: exact text, label, or notice as presented, saved as a file with its start date. 2. Placement record: where it appears (page, flow, message), with a dated screenshot or the saved step in the job record. 3. Coverage list: the outputs and interactions the disclosure covers. 4. Marking record: for generated content in scope, the marking method used and an example as published. 5. Change log: every surface change that moved or altered the disclosure, with dates. Review: on every surface change, and quarterly.
Worked example
Sample: a consultancy's client-facing research bot opens each engagement with a disclosure message saved as the first step of the job record; the handover the client receives therefore carries the disclosure inside the same object that proves the work. When the question "were we told this was AI?" is asked months later, the answer is a link, not an argument. (Sample scenario; the duty summary is the general one in the scope line.)
Frequently asked questions
Do the August 2026 duties apply to small teams outside the EU?
The Act's reach depends on where your users and outputs are, not only where you sit, and that analysis is situation-specific. The record habit on this page is cheap insurance either way: disclosures you can show, dated, in context.
Is a disclosure in our terms of service enough as a record?
Terms prove a disclosure exists in a document. The records here prove it was presented on a surface, from a date, covering named outputs, which is the question an inquiry actually asks. Keep both.
What changed for Article 50 in the Digital Omnibus?
The Omnibus moved the Annex III high-risk application dates (to 2 December 2027) while the Article 50 transparency duties keep their August 2026 start. Treat disclosure records as a 2026 task, not a 2027 one.
By Brennan Zambo, founder of Zambo.
Last verified: 2026-10-17.
Try a handover
A handover gives your client one proof link with verifiable receipts to review, then Accept or Flag.
try it: say 'use zambo to hand this over to <client>' in your ai