# AI Transparency — legal context bundle > Curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/topics/transparency-obligations-ai-systems > Sources are cited per item. Verify against the official texts before relying on them. This new topic is needed to specifically capture the transparency obligations framework for AI systems providers and deployers, which is a distinct and comprehensive requirement under the AI Act that encompasses disclosure of system characteristics, performance metrics, limitations, and intended use to end-users and relevant stakeholders. ## Overview ## Legal Framework Article 50 of the AI Act establishes the core transparency obligations for providers and deployers of certain AI systems. It mandates that providers of AI systems intended to interact with natural persons, emotion recognition systems, biometric categorization systems, and AI systems that generate or manipulate image, audio, or video content ("deepfakes") must ensure transparency to end-users. The required disclosures, detailed in Article 50(1) and (2), include informing individuals that they are interacting with an AI system, the system's intended purpose, and its capabilities and limitations. For generated content, the provider must ensure the output is marked as artificially generated or manipulated. Deployers of these systems, as per Article 50(3), must notify a natural person when they are exposed to an emotion recognition or biometric categorization system. Furthermore, Article 50(5) requires deployers of AI systems that generate deepfake content to disclose the artificial nature of that content, unless use is authorized for law enforcement or the content is part of an obvious artistic or creative work. ## Practical Application The provision creates a distinct, purpose-built transparency regime for specific AI applications where a lack of clarity could deceive or manipulate individuals, undermining their autonomy. While the authoritative Tekst & Commentaar on the GDPR clarifies transparency as a fundamental principle for data processing, the AI Act's framework is tailored to the unique risks of AI interaction and content generation, operating alongside but separately from GDPR obligations. The practical burden differs: providers must design systems with transparency in mind (e.g., building in disclosure mechanisms), while deployers have operational duties to activate these disclosures or provide their own notifications. Enforcement will focus on whether the required information is communicated in a clear, timely, and meaningful way to the affected individual. ## Key Considerations * **Mapping Obligations by Role:** Organizations must first determine if they act as a "provider" or "deployer" under the AI Act for their AI systems and then apply the specific transparency duties attached to that role and system type (e.g., interaction, emotion recognition, deepfake generation). * **Integrating with GDPR:** For AI systems that also involve personal data processing, the transparency requirements under Article 13 GDPR (providing information to data subjects) continue to apply and must be coordinated with, not replaced by, the AI Act's Article 50 disclosures. * **Technical Implementation for Providers:** Providers of in-scope systems must design technical solutions to embed disclosures (e.g., real-time notifications for AI interaction) or output markings (e.g., watermarking for generated content) directly into the system or its outputs to enable compliance by deployers. ## Legislation (full text of key provisions) ### Recital 101 — General-purpose AI model provider transparency obligations *Source: AI Act, aiact-rec-101-en, 2024-06-12 — https://overview.legal/posts/93884* Providers of general-purpose AI models have a particular role and responsibility along the AI value chain, as the models they provide may form the basis for a range of downstream systems, often provided by downstream providers that necessitate a good understanding of the models and their capabilities, both to enable the integration of such models into their products, and to fulfil their obligations under this or other regulations. Therefore, proportionate transparency measures should be laid down, including the drawing up and keeping up to date of documentation, and the provision of information on the general-purpose AI model for its usage by the downstream providers. Technical documentation should be prepared and kept up to date by the general-purpose AI model provider for the purpose of making it available, upon request, to the AI Office and the national competent authorities. The minimal set of elements to be included in such documentation should be set out in specific annexes to this Regulation. The Commission should be empowered to amend those annexes by means of delegated acts in light of evolving technological developments. ### Recital 137 — transparency compliance not implying lawfulness *Source: AI Act, aiact-rec-137-en, 2024-06-12 — https://overview.legal/posts/93956* Compliance with the transparency obligations for the AI systems covered by this Regulation should not be interpreted as indicating that the use of the AI system or its output is lawful under this Regulation or other Union and Member State law and should be without prejudice to other transparency obligations for deployers of AI systems laid down in Union or national law. ### Recital 72 — transparency requirements for high-risk AI systems *Source: AI Act, aiact-rec-72-en, 2024-06-12 — https://overview.legal/posts/93826* To address concerns related to opacity and complexity of certain AI systems and help deployers to fulfil their obligations under this Regulation, transparency should be required for high-risk AI systems before they are placed on the market or put it into service. High-risk AI systems should be designed in a manner to enable deployers to understand how the AI system works, evaluate its functionality, and comprehend its strengths and limitations. High-risk AI systems should be accompanied by appropriate information in the form of instructions of use. Such information should include the characteristics, capabilities and limitations of performance of the AI system. Those would cover information on possible known and foreseeable circumstances related to the use of the high-risk AI system, including deployer action that may influence system behaviour and performance, under which the AI system can lead to risks to health, safety, and fundamental rights, on the changes that have been pre-determined and assessed for conformity by the provider and on the relevant human oversight measures, including the measures to facilitate the interpretation of the outputs of the AI system by the deployers. Transparency, including the accompanying instructions for use, should assist deployers in the use of the system and support informed decision making by them. Deployers should, inter alia, be in a better position to make the correct choice of the system that they intend to use in light of the obligations applicable to them, be educated about the intended and precluded uses, and use the AI system correctly and as appropriate. In order to enhance legibility and accessibility of the information included in the instructions of use, where appropriate, illustrative examples, for instance on the limitations and on the intended and precluded uses of the AI system, should be included. Providers should ensure that all documentation, including the instructions for use, contains meaningful, comprehensive, accessible and understandable information, taking into account the needs and foreseeable knowledge of the target deployers. Instructions for use should be made available in a language which can be easily understood by target deployers, as determined by the Member State concerned. ## Recent developments ### AI Omnibus: Reject the proposals to undermine transparency in the AI Act *Source: European Digital Rights, 2026-02-11 — https://overview.legal/posts/52497 — original: https://edri.org/our-work/ai-omnibus-reject-the-proposals-to-undermine-transparency-in-the-ai-act/* The European Commission’s dangerous and misguided Digital Omnibus proposal includes a dangerous rollback of transparency requirements in the AI Act. 60 civil society organisations, independent public authorities and individuals, including EDRi, urge EU lawmakers to reject a change that would risk weakening enforcement, legal certainty, and the protection of fundamental rights, while offering negligible benefits for companies. The post AI Omnibus: Reject the proposals to undermine transparency in ### Is the AI Act caging ChatGPT and other General Purpose Artificial Intelligence systems? *Source: Gaming Tech Law, 2023-03-29 — https://overview.legal/posts/6223 — original: https://www.gamingtechlaw.com/2023/03/draft-ai-act-general-purpose-artificial-intelligence/#entry-4244* > The growth of generative artificial intelligence systems has led EU lawmakers to focus on General Purpose AI in drafting the AI Act, which will set the framework governing artificial intelligence in the European Union. As previously reported, the EU Parliament has already broadened the definition of artificial intelligence for the purposes of the AI Act… ## Related topics - **Transparency** — https://overview.legal/topics/transparantie Openness about data processing activities - **AI Provider Transparency** — https://overview.legal/topics/transparency-obligations-providers-deployers-ai This specific topic is needed to comprehensively cover the transparency obligations framework that applies to both providers and deployers of AI systems, which - **AI Value Chain Actors and Roles** — https://overview.legal/topics/ai-value-chain-actors The content focuses on responsibilities distributed across different actors in the AI value chain. 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