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ARTICLE · 17 JUNE 2026

Part 2: AI Act Articles 50(3) And 50(4) Transparency Obligations

William Fry LLP
William Fry LLP
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William Fry LLP

William Fry LLP

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The European Commission has issued interpretive guidelines on Article 50 of the AI Act, clarifying transparency obligations for emotion recognition systems, biometric categorization, and deepfake content.

IrelandPrivacy
Barry Scannell
Barry Scannell
Rachel Hayes
Rachel Hayes
Leo Moore
Leo Moore
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In Part 1 of this series, we examined commentary by the Commission to assist in navigating concepts of Article 50 that were initially unclear.

We also discussed the Commission’s interpretation of Articles 50(1) and 50(2), including disclosure obligations for AI-human interactions, the narrow scope of the “obviousness” exception, and the marking requirements for AI-generated or manipulated content. We also considered the treatment of GPAI, open-source and agentic AI systems, and the limited exclusions identified in the Guidelines.

Part 2 of this series examines the remaining transparency obligations under Article 50, focusing on emotion recognition and biometric categorisation systems under Article 50(3), alongside the disclosure requirements for deepfakes and AI-generated content informing matters of public interest under Article 50(4). It also considers the practical operation of the artistic and satirical carve-outs, retrospective labelling expectations, and the emerging Code of

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