EU AI Act Transparency Toolkit

Prepare for Article 50 transparency obligations

The EU AI Act introduces a transparency regime that will apply from 2 August 2026 (with extensions for certain existing systems). It will affect organisations developing or using a wide range of AI systems across the EU. Many organisations with an EU nexus will need to assess their systems against the transparency obligations, determine their role, and implement appropriate disclosures and/or technical measures.

What does the transparency regime require?

Article 50 of the EU AI Act introduces four transparency obligations:

• Interactive AI (e.g. chatbots)
  → Clear disclosure that users are interacting with AI
• Generative AI systems
  → Digital marking of AI-generated content
• Emotion recognition and biometric categorisation systems
  → Disclosure to individuals exposed to these systems
• Deepfake and synthetic content systems
  → Labelling of AI-generated or manipulated content

Who is this for?

The Transparency Toolkit is relevant to any organisation developing or using AI systems in the EU.

The Toolkit supports cross-functional teams, including legal, product, and engineering, who need to work together to deliver practical compliance outcomes.

What the Toolkit includes

The Toolkit combines legal and practical guidance, templates and implementation advice designed to achieve a smooth compliance process.

Phase I: Understand the regime

Build a clear, practical understanding of Article 50 requirements and key concepts.

• Transparency Cheat Sheet: Transparency regime at a glance
• Transparency Training Deck: Ready-made slides for internal training
• Transparency Checklist: Key points to ensure compliance

Phase II: Identify in-scope systems

Work through your AI tools to determine which ones fall within scope.

• Transparency Scoping Questionnaire: Key document to assist in identifying in-scope systems and uses. Business-friendly, with comprehensive guidance and examples to ensure accurate scoping

Phase III: Understand your role

Assess whether you are acting as a provider, deployer, or both for the in-scope systems (and which obligations you need to comply with).

• Provider / Deployer Guidance Note: Explains when organisation will be provider or deployer for transparency regime, with guidance and examples
• Provider / Deployer Checklist: Practical tool to identify provider or deployer role

Phase IV: Implement compliance steps

Put in place appropriate disclosures, labelling, and technical mechanisms to meet the requirements of the EU AI Act.

• Art 50(1): Labelling Guidance: Guidance, practical examples and template wording for various systems / scenarios to ensure users are clearly informed when interacting with AI
• Art 50(2): Digital Marking Guidance: Guidance and technical suggestions to implement digital marking for AI systems, depending on content modality and nature of the system
• Art 50(3): Disclosure Guidance for Biometric Categorisation and Emotion Recognition: Guidance, practical examples and template wording for various systems / scenario to ensure compliant disclosures
• Art 50(4): Deepfake Labelling Guidance & Internal Policy: Guidance (with examples and templates) for labelling deep fakes + internal policy to ensure compliance when using third-party systems to generate / modify deep fakes
• Art 50(4): Public Interest Text Labelling Guidance: Guidance (with examples and templates) for labelling public interest text

There are two regulatory documents that provide guidance on these obligations (final versions expected in June 2026):

• Transparency Guidelines
• Transparency Code of Practice

Our Transparency Toolkit incorporates recommendations from both documents, ensuring your organisation’s practices are aligned with regulatory expectations and can be implemented in a practical and defensible way

Our expertise

Simmons & Simmons is widely recognised as a leading adviser on AI regulation and governance.

• Band 1 – Artificial Intelligence, Legal 500 UK (2025–2026)
• Global Market Leaders – Artificial Intelligence, Chambers (2025–2026)
• FT Innovative Lawyer Awards – Innovation in AI tools (2025)

We bring together regulatory, technical and operational expertise through a multidisciplinary team of lawyers, AI specialists and data professionals.

Ready to learn more?

For enquiries about the Toolkit and pricing information, please complete the form below.