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Which Article 50 duties apply to your AI feature?

Article 50 of the EU AI Act applies from 2 August 2026. Whether it imposes any duty on your product — and in which role — depends on what the feature does. Answer seven questions; every conclusion carries its article.

Legal basis: Regulation (EU) 2024/1689 verified against the Official Journal, as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI, OJ 24 July 2026, in force 27 July 2026) · Not legal advice.

Is your product placed on the EU market, or is its output used in the EU?

Selling to EU customers counts. So does output that reaches people in the EU — the Act's two extraterritorial reach triggers (Art. 2(1)(a), (c)).

Is your company established in the EU, or are you located there?

A separate reach trigger: the Act applies to “deployers of AI systems that have their place of establishment or are located within the Union” (Art. 2(1)(b)) — regardless of where your product is sold.

Do you ship the AI feature under your own brand?

Integrating GPT, Claude or any foundation model into your product and placing it on the market under your own name or trademark makes you the provider of the resulting system (Art. 3(3)) — not a mere deployer of someone else's model.

Does the feature interact directly with people? (chatbot, assistant, voice agent)

Anything a customer or end user converses with.

Does it generate synthetic content — text, images, audio or video?

Any generated or manipulated audio, image, video or text counts — Article 50(2) has no "realism" threshold.

Do you operate emotion recognition or biometric categorisation on people?

As the organisation exposing people to such a system (deployer duty).

Do you create or share deepfakes, or publish AI-generated text informing the public on matters of public interest?

Deployer disclosure duty; exceptions exist for creative/satirical works and human-reviewed editorial text.
Your Article 50 map
Get this map as a written report

Your duties above, plus the questionnaire questions each one triggers when a buyer runs a vendor review. One email, nothing else — no list, no follow-ups unless you reply.