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ClearLabel — EU AI Act Article 50 transparency check

Free scanner + open vendor dataset for the AI-disclosure rule that has applied since 2 August 2026.

👉 Run a scan — no signup, nothing stored, runs in your browser.


Why this exists

Most EU AI Act tooling is built around high-risk (Annex III) obligations. The Digital Omnibus, given final Council approval on 29 June 2026, deferred most of those to 2 December 2027.

Article 50 transparency was not deferred. It has been binding since 2 August 2026:

Date What applies
2 Aug 2026 Art. 50(1) — people must be informed they are interacting with an AI system, unless obvious. Art. 50(4) — deepfake and public-interest AI text disclosure.
2 Dec 2026 Art. 50(2) — machine-readable marking of synthetic audio/image/video/text. Four-month transition for systems already on the market before 2 Aug 2026.
2 Dec 2027 Most standalone high-risk obligations (deferred by the Digital Omnibus).

If you enabled an AI agent in Zendesk, Intercom, Gorgias, Tidio, Crisp or HubSpot, you are the deployer and the duty is yours, not your vendor's.

What the scanner does

  1. Fetches the public HTML of a URL.
  2. Fingerprints known conversational-AI vendors (36 and counting).
  3. Searches visible page copy for AI-disclosure wording in 10 EU languages.
  4. Reports per-article findings with an explicit confidence level.

It deliberately does not claim you are non-compliant. It reports what the page source does and does not show, and what that means you need to confirm.

Limits, stated up front

  • Homepage-only unless you pass a deeper URL. Widgets usually live on /contact or /help.
  • Cannot see widgets injected later by a tag manager.
  • Cannot open your chat widget or read your vendor console, so it cannot tell whether your AI mode is switched on.
  • Heuristics, not an audit. Not legal advice.

The dataset

data/vendors.jsonCC-BY-4.0. Each vendor carries:

{
  "id": "crisp",
  "name": "Crisp",
  "aiNature": "ai-optional",        // ai-native | ai-optional | rule-based | content-gen
  "aiProduct": "MagicReply / Crisp AI",
  "patterns": ["client\\.crisp\\.chat", "\\$crisp"],
  "disclosureHook": "Operator nickname + welcome message in Crisp settings"
}

aiNature is what drives the Article 50(1) reasoning:

  • ai-native — the product is an LLM agent by design. The duty applies.
  • ai-optional — vendor ships both scripted and AI modes. The duty applies if AI mode is on; only the operator can confirm.
  • rule-based — scripted flows. Art. 50(1) can still bite where the interface reads as human.

PRs adding vendors are welcome. Add the fingerprint, the aiNature, and where in that vendor's console the disclosure actually goes.

CLI

node scanner/scan.mjs example.com
node scanner/scan.mjs @sites.txt > results.jsonl

Outputs JSONL. The CLI and the browser app import the same scanner/core.mjs, so verdicts are identical by construction.

Measured base rate

Full write-up and open data: https://clearlabel.eu/study/

Scanned 883 EU sites on 16-17 Aug 2026, 667 of them readable, across two sampling frames:

Frame Scanned Readable Runs a chat/AI widget Of those, no disclosure
Tranco top EU ccTLDs 703 532 4.9% 92.3%
Independent EU online shops 180 135 24.4% 97.0%
Combined 883 667 8.8% 94.9%

Widget density is five times higher among online shops than across general EU sites, so the Tranco figure is a floor, not a market estimate. Only 0.4% of all readable sites carried any machine-readable AI-content marking ahead of the 2 December 2026 deadline.

Raw per-domain results in study/.

Disclaimer

ClearLabel provides structured information and document drafts. It is not a law firm and this is not legal advice. Penalties under Art. 99(4) are set nationally and capped at €15m or 3% of worldwide turnover. For a binding view on your exposure, consult a qualified adviser in your member state.

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Free EU AI Act Article 50 transparency scanner + open vendor fingerprint dataset. The AI-disclosure rule has applied since 2 Aug 2026.

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