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Do you know when you are talking to a machine?

4 September 2026 · 1 min

Since 2 August 2026 the transparency obligations in Article 50 of the AI Act apply.

The principle is clear. Providers of systems intended to interact directly with people must ensure that those people are informed that they are interacting with an AI system. With one exception: when this is obvious from the point of view of a reasonably well-informed, observant and circumspect person, taking into account the circumstances and the context of use.

There is also a rule for content. Those who use a system to generate or manipulate image, audio or video content constituting a deep fake must disclose that the content has been artificially generated or manipulated.

The critical point

A transparency rule is only as good as its intelligibility. A notice nobody sees does not inform. A label in small print at the bottom of the page respects the letter and betrays the purpose.

The "reasonably well-informed" person test helps, but it moves the question. Who is reasonably well-informed when a synthetic voice calls them? An elderly person? A child? Someone tired at eleven at night?

For me the answer lies in method. Writing the notice is not enough. We need to check that people see it and understand it. It can be tested, like any interface.

Transparency is not saying something. It is making sure it gets through.

Let’s discuss

Who should prove that a transparency notice was actually understood: the one who writes it or the one who receives it?

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Personal reflection, not legal advice.

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