EU AI Act Compliance
AI Disclosure Generator for Developers
The EU AI Act requires transparency when users interact with AI systems. Most teams do not know which of their dependencies trigger disclosure obligations. Codepliant scans your codebase, detects every AI integration, and generates the required disclosure documents automatically.
Why AI disclosure is mandatory by August 2, 2026
The EU AI Act (Regulation 2024/1689) entered into force on August 1, 2024. Article 50 transparency obligations apply from August 2, 2026 — regardless of your AI system's risk classification. Unlike the high-risk provisions that take effect later, transparency applies to almost every application that uses AI in any form.
The Act has extraterritorial scope. If your product is accessible to people in the EU, you must comply — even if your company is based in the US, UK, or elsewhere. This mirrors GDPR's approach and means most SaaS products, mobile apps, and web applications with AI features fall within scope.
Penalties for non-compliance
Fines for transparency violations can reach up to 15 million EUR or 3% of global annual turnover, whichever is higher. National market surveillance authorities in each EU member state are responsible for enforcement.
What an AI disclosure must contain (Article 50)
Article 50 defines specific transparency obligations depending on how AI is used in your application. Every AI disclosure must address the relevant requirements below:
AI interaction notification
Users must be informed, clearly and before interaction begins, that they are communicating with an AI system. This covers chatbots, virtual assistants, AI-powered support, and any interface where a user might reasonably believe they are interacting with a human (Art. 50(1)).
AI-generated content marking
Text, images, audio, and video generated or substantially modified by AI must be labeled as AI-generated. This includes deepfakes, synthetic media, AI-written articles, and AI-generated code. The marking must be machine-readable where technically feasible (Art. 50(2)).
Emotion recognition and biometric disclosure
If your system uses emotion recognition or biometric categorization, you must inform individuals that such processing is taking place and explain its purpose. This applies even when the system is not classified as high-risk (Art. 50(3)).
AI capabilities and limitations
Deployers must provide information about what the AI system can and cannot do, including known limitations, accuracy levels, and potential failure modes. This helps users form appropriate expectations about AI-generated outputs.
Purpose and scope of AI use
A clear statement of why AI is used, what data it processes, and the scope of decisions it influences. If AI assists in decisions affecting individuals (hiring, credit, content moderation), the AI's role must be specifically disclosed.
Human oversight mechanisms
Where relevant, disclosures should describe what human oversight exists over AI outputs — whether AI suggestions are reviewed by humans, how users can request human review, and how errors are corrected.
The specific obligations that apply depend on how AI is used in your application. A chatbot requires interaction disclosure. An AI image generator requires content marking. A product using both needs both. Codepliant detects which obligations apply based on the AI services it finds in your code.
How Codepliant detects AI services and generates disclosures
Instead of asking you to list your AI integrations, Codepliant reads your codebase and finds them. Here is what happens when you run the CLI:
Scan dependencies for AI packages
Codepliant reads your package.json, requirements.txt, go.mod, Cargo.toml, or equivalent and matches against known AI service packages — openai, @anthropic-ai/sdk, @google/generative-ai, transformers, langchain, replicate, and dozens more.
Scan source code imports
Dependencies alone miss some AI integrations. Codepliant also scans your source files for import and require statements that reference AI libraries, catching direct API calls and vendored modules that are not listed as top-level dependencies.
Scan environment variables
AI services require API keys. Codepliant scans your .env files and configuration for patterns like OPENAI_API_KEY, ANTHROPIC_API_KEY, GOOGLE_AI_KEY, HUGGING_FACE_TOKEN, and REPLICATE_API_TOKEN to detect services even when the SDK is abstracted away.
Map detections to Article 50 obligations
Each detected AI service is categorized by type: conversational AI, content generation, image generation, speech-to-text, embeddings, model inference. Each type maps to specific Article 50 transparency obligations — chatbot detection triggers interaction disclosure requirements, image AI triggers content marking requirements.
Generate disclosure documents
Codepliant produces an AI Disclosure (user-facing transparency notice), an AI Checklist (internal compliance checklist), an AI Model Card (technical documentation), and AI-specific sections for your privacy policy. Every document names the specific services found in your code.
AI integrations Codepliant detects
No disclosure vs. Codepliant-generated
Here is what most applications look like today versus what Article 50 requires — shown for a Next.js app using OpenAI for chat, DALL-E for image generation, and Anthropic Claude for content summarization.
No AI disclosure exists. Users interact with AI-powered chat without knowing it is AI. AI-generated images are displayed without labels. Summaries produced by Claude appear as if written by the platform. The privacy policy mentions "automated processing" but does not name any AI systems or describe their capabilities.
This is the current state for the majority of applications using AI APIs.
AI Systems Used in This Application
Conversational AI (via OpenAI GPT-4): Our chat feature is powered by OpenAI's GPT-4 model. When you use chat, your messages are processed by this AI system. Responses are generated by AI, not written by humans. The AI may produce inaccurate or incomplete information.
AI Image Generation (via OpenAI DALL-E): Images created through our platform are generated by OpenAI's DALL-E model. All AI-generated images are labeled as such and include machine-readable metadata per Art. 50(2).
Content Summarization (via Anthropic Claude): Article summaries and content digests are produced by Anthropic's Claude model. These summaries are AI-generated and may not capture all nuances of the source material.
Human Oversight
AI-generated content is not reviewed by humans before display. Users can report inaccurate AI outputs via the feedback button. Our team reviews flagged content within 48 hours.
Data Processing
Chat messages are sent to OpenAI, Inc. (San Francisco, CA). Content for summarization is sent to Anthropic, PBC (San Francisco, CA). International transfers are governed by Standard Contractual Clauses (SCCs). See our Privacy Policy for details.
The difference: Without a disclosure, users have no idea they are interacting with AI — a direct violation of Article 50(1). Codepliant names each AI system, describes what it does, acknowledges limitations, identifies the provider companies, and discloses data transfers. It generates this from what it finds in your code, not from a questionnaire.
Documents generated for AI compliance
User-facing transparency notice listing every AI system, its purpose, capabilities, limitations, and the provider. Designed to satisfy Article 50 interaction and content labeling requirements.
Internal compliance checklist mapping each detected AI integration to specific Article 50 obligations. Helps your team verify that all transparency requirements are met before the August 2026 deadline.
Technical documentation of AI models used — their capabilities, training data provenance (where known), performance characteristics, and known limitations. Useful for internal governance and audits.
AI-specific data processing disclosures integrated into your privacy policy — which AI providers receive user data, what data is sent, how it is processed, and international transfer mechanisms.
Generate your AI disclosure before August 2, 2026
Scan your codebase for AI integrations and generate Article 50 compliant disclosure documents. Names your actual AI services, maps transparency obligations, and produces ready-to-publish documents.
Free, open source, no account required. Works offline.
Frequently asked questions
What is Article 50 of the EU AI Act?
Article 50 of the EU AI Act establishes transparency obligations for providers and deployers of AI systems. It requires that users are informed when they are interacting with AI, when content is AI-generated, and when AI systems are used for decision-making that affects them. These obligations apply broadly — not just to high-risk AI systems.
When does Article 50 take effect?
Article 50 transparency obligations take effect on August 2, 2026. Organizations using AI in products or services available to EU citizens must comply by this date. This applies regardless of where your company is headquartered — if EU residents use your product, you must comply.
Does the EU AI Act apply to my application?
If your application uses AI and is accessible to users in the EU, you likely need to comply. This includes chatbots, AI-generated content, recommendation systems, automated decision-making, and any feature powered by large language models like GPT-4, Claude, or open source models. The Act has extraterritorial scope similar to GDPR.
What AI integrations does Codepliant detect?
Codepliant detects OpenAI API (GPT-4, DALL-E, Whisper), Anthropic Claude, Google AI/Gemini, Hugging Face Transformers, Replicate, Cohere, AI21 Labs, Stability AI, local model inference (ONNX, TensorFlow, PyTorch), LangChain, LlamaIndex, and other AI/ML frameworks in your codebase. Detection covers dependencies, source code imports, and environment variables.
What documents does Codepliant generate for AI compliance?
Codepliant generates AI Disclosure documents (user-facing transparency notices), AI Checklists (internal compliance checklists), AI Model Cards (technical documentation of AI models used), and AI-specific sections in your privacy policy. Together these cover Article 50 requirements including transparency notices, capability descriptions, and risk assessments.
What penalties apply for non-compliance with Article 50?
Non-compliance with EU AI Act transparency obligations can result in fines up to 15 million EUR or 3% of global annual turnover, whichever is higher. For comparison, GDPR fines cap at 20 million EUR or 4% of turnover. National market surveillance authorities in each EU member state will enforce these requirements.
Is the AI disclosure generator free?
Yes. Codepliant is open source (MIT licensed) and completely free. Run npx codepliant go in your project directory and all compliance documents — including AI disclosures — are generated locally. No account, no API key, no network calls.
How is this different from manually writing an AI disclosure?
Manually writing an AI disclosure requires you to know every AI integration in your codebase, understand what Article 50 requires for each type, and keep the document updated as your stack changes. Codepliant automates all three: it detects AI services from your code, maps them to Article 50 requirements, and regenerates when your dependencies change.
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