Guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act — C(2026) 5054 final, Annex

(143) Article 50(5) AI Act requires the information to be provided to the natural persons concerned at the latest at the time of the first interaction or exposure. The first interaction or exposure refers not only to the first natural person interacting with or exposed to (the output of) an AI system, but also any subsequent, first interaction with or exposure to (the output of) the AI system by any other natural person. As regards the first interaction with an AI-system, the information should, at least, be provided once at the start of an interactive session, while considering the specific contexts mentioned in point above. As regards AI-generated or manipulated content falling within the scope of Article 50(2) and

(4) AI Act, the information obligation applies to each output of an AI system with respect to any natural person exposed to the content. It should be understood in the sense of any moment in time at which a natural person is reasonably likely to be exposed to the output of the AI system and perceive the disclosure, taking into account the specificities of disclosure in case of evidently creative, artistic and other works (see Section 6.1.3.). Moreover, deployers are allowed to inform natural persons earlier than the first actual interaction or exposure (e.g. at the beginning of content featuring deep fakes). However, if it is reasonably foreseeable that persons may not perceive content from its beginning, then only disclosure at the beginning of content does not adequately inform those persons and should be complemented with disclosure at later moments, where possible. This may be implemented as appropriate, taking into account the objective of the transparency obligations to ensure an effective provision of the information and meaningful user awareness in increasingly immersive and realistic AI environments where users have

(40) When children are part of the target audience of the content those notifications must be: (i) child-friendly, age-appropriate, easy-to-understand and easily accessible to all children, including those with disabilities and/or additional accessibility needs; (ii) presented clearly in a way that is easy to understand and is as simple and succinct as possible; (iii) presented in ways that are easy to review and that provide for immediate and intuitive access, at the points at which they become relevant; (iv) presented in the official language(s) of the Member State the service is provided in; (v) engaging for children. This may also include the use of graphics, videos, and/or characters or other techniques; (vi) given to children gradually and overtime to maximise retention by the user.

increasing difficulties to distinguish the origin and the truthfulness of the content and the interaction. Examples of information provision at the first interaction or exposure under Article 50(5) AI Act

- First interaction: when launching a conversation with a chatbot or starting physical interaction with an AI system.

- First exposure: at the start of a video featuring a deep fake, at the start of an AI-generated or manipulated text publication on matters of public interest, or when encountering AI- manipulated deep fakes when scrolling on social media.