Mandatory Transparency in AI Assistants: What Article 50 of the AI Act Requires from August 2026

The 2nd of August 2026 marked the start of the application of the transparency obligations established in Article 50 of Regulation (EU) 2024/1689, known as the AI Act. This date is not arbitrary: it represents the point at which European legislation moved from a theoretical framework to a binding legal requirement for any artificial intelligence system that interacts directly with people in the European market.

The European Commission adopted the final guidelines on these obligations on July 20, 2026, closing the interpretative framework that accompanies the legal text. These guidelines, along with the Code of Good Practices on the Transparency of AI-Generated Content, published on June 10, 2026, provide the operational basis for providers and professional users to understand exactly what is expected of them.

It is crucial to distinguish between the adoption date of the guidelines and the effective application date. While the regulatory documents were approved in July, the obligations are enforceable from August. This temporal separation allows organizations an adaptation period, but it does not eliminate legal responsibility once that period has passed.

Providers of AI systems designed to interact directly with people—such as chatbots, virtual assistants, or avatars—must ensure that the user is explicitly informed that they are interacting with an artificial intelligence system. This obligation has a single exception: when it is evident, considering the circumstances and the context of use, that it is an automated system.

In addition to identifying the artificial origin, providers must add machine-readable marks to content generated or manipulated by AI. These marks allow for the technical detection of synthetic content, facilitating subsequent verification by third parties, distribution platforms, or end users who use analysis tools.

The regulation does not limit itself to real-time interaction. It also requires providers to document the capabilities and limitations of their systems, including known risks associated with the use of the assistant. This information must be available in an accessible manner so that professional users can adequately assess the risk before integrating the tool into their workflows.

For the end user, the most visible change will be the clarity in identification of the assistant. Tools like ChatGPT, Gemini, and Copilot already implement identification mechanisms, but European regulation elevates this standard to a legal obligation with associated sanctions. This means that the absence of a clear indication is not just a design bad practice, but a regulated infringement.

The obligation to declare limits and risks modifies the trust relationship between the user and the tool. Instead of relying on the manufacturer's reputation or the user's subjective perception, the regulation requires an explicit declaration of what the assistant can and cannot do. This includes, for example, warnings about the possibility of factual errors, limitations in temporal knowledge, or restrictions in processing sensitive data.

The impact varies depending on the type of assistant. General-purpose assistants, such as ChatGPT or Gemini, face broader requirements due to their versatility. Specialized assistants, such as those integrated into corporate environments, may have more specific obligations related to the context of use and the data they process. In both cases, transparency must be proportional to the risk and the scope of the interaction.

One of the most practical contributions of Article 50 is the obligation to declare known limitations. This includes, among other things, the possibility that the system generates inaccurate information, the limitation of its knowledge to a specific cutoff date, or restrictions in handling personal or sensitive data. This declaration is not optional: it is a legal requirement that must be available to the user.

The regulation also requires transparency regarding the use of training data and the security measures implemented to protect user privacy. If an assistant uses data from previous conversations to improve its responses, this practice must be communicated to the user, along with the available options to disable it or delete their data.

These limit declarations are not merely informative: they have practical consequences for decision-making. A user who knows that an assistant has limited knowledge up to a specific date may decide not to use it for queries about recent events. A professional who knows the limitations in handling sensitive data can avoid introducing confidential information into the tool. Transparency, in this sense, empowers the user to make informed decisions.

To verify if an AI assistant meets the transparency requirements of Article 50, the user can follow a series of specific steps. First, they must check that the identification as an AI system is clear and visible from the start of the interaction. This includes not only an initial notice, but also continuous indications that allow the user to remain aware that they are interacting with an automated system.

Second, they must look for the documentation of capabilities and limitations. This information is usually available on the help page, in the terms of service, or in a specific transparency section of the provider. The documentation must be accessible, up-to-date, and written in language understandable to the non-technical user.

Third, the user can verify the presence of machine-readable marks in the generated content. Although these marks are not visible to the end user, their presence can be confirmed through analysis tools or by requesting information from the provider about the technical measures implemented. For professional users, this verification is especially relevant when integrating the assistant into workflows that generate publicly distributed content.

Finally, the user must check that the provider offers clear contact and complaint mechanisms. European regulation not only requires transparency, but also the possibility for users to exercise their rights, including the rectification of inaccurate information or the deletion of personal data. The absence of these mechanisms is a warning sign regarding overall compliance with the regulation.

Non-compliance with the transparency obligations of Article 50 can result in fines of up to 15 million euros or 3% of the annual global turnover, whichever is higher. This figure is not symbolic: it represents a significant penalty that deters providers from ignoring their obligations. For professional users, the risk is not only legal, but also reputational: using an assistant that does not comply with the regulation can expose the organization to public criticism and the loss of trust from clients and partners.

The application of these sanctions is the responsibility of the national supervisory authorities designated by each EU member state. In Spain, the Spanish AI Supervisory Agency (AESIA) is the competent body. Users who detect non-compliance can file complaints with this authority, which has the power to investigate and sanction the responsible providers.

Looking ahead, European regulation establishes a framework that will evolve with technology. The guidelines adopted in July 2026 are the starting point, but the European Commission is expected to update these guidelines as new types of AI systems and new forms of interaction emerge. Users and providers must stay informed about these updates to ensure continuous and adapted compliance with the changing circumstances of the market.