EU AI Act Article 50 — Transparency Guide

Version: 1.0

Effective: 2 August 2026

Owner: Legal / Product — Touch2Sign Ltd

Audience: Customers (deployers), procurement, compliance reviewers

Internal analysis: ../EU_AI_ACT_ARTICLE_50.md

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Purpose

This guide explains how Touch2Sign meets the transparency obligations in Article 50 of the EU AI Act (Regulation (EU) 2024/1689), and what customers should do when using Aria AI and Sentinel AI features.

It is not a claim that every Touch2Sign workflow is a high-risk AI system under Annex III. It covers transparency for AI features that interact with people or generate content.

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What Article 50 requires (summary)

1. Tell people when they are interacting with an AI system, unless obvious from the context.
2. Mark synthetic content (AI-generated or manipulated text, image, audio, or video) so it is detectable in a machine-readable way, where technically feasible.
3. Extra rules apply to emotion recognition, biometric categorisation, deepfakes, and certain public-interest text — Touch2Sign does not offer those features.

Obligations apply from 2 August 2026. A limited grace period to 2 December 2026 may apply only to Article 50(2) marking for generative systems already on the market before 2 August 2026. Touch2Sign implements marking for Aria drafts from the effective date.

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AI features in Touch2Sign

Feature	What it does	Who sees it
Aria — draft	Generates a first-draft document from a natural-language prompt	Senders
Aria — signing analysis	Pre-send analysis: reading time, key clauses, risk flags, signer briefing	Signers (briefing)
Aria — summary & Q&A	Plain-language summary and questions about the document during signing	Signers
Sentinel — risks	Extracts and classifies risks from signed / stored documents	Customer operators
Sentinel — Ask / search	Natural-language Q&A across contracts	Customer operators

All AI processing for these features runs on AWS Bedrock in eu-west-1 (Claude). Customer document content is not used to train foundation models. See the Data Processing Agreement and sub-processor register.

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How Touch2Sign complies

Informing people (Article 50(1))

• Signers see a platform AI & Signing Analysis Disclosure in the consent step (alongside ERSD / Part 11 where applicable). Expanding it is recorded in the audit trail.
• Signer briefing states that analysis is powered by Touch2Sign AI and is guidance only.
• Senders see clear Aria branding when drafting with AI.
• Sentinel users see an on-screen notice that they are interacting with an AI system.

Marking AI-generated drafts (Article 50(2))

When Aria generates a document draft, Touch2Sign embeds:

• A machine-readable HTML comment (t2s-ai-generated:1 …), and
• A visible banner with data-ai-generated="true" stating the content was artificially generated.

Senders should review and edit AI drafts before sending. After human editing, the banner may be removed; the signed PDF reflects the final human-approved content.

What we do not do

• Emotion recognition or biometric categorisation AI
• Deepfake image/audio/video generation
• Automated legal advice or binding validity opinions

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Customer (deployer) responsibilities

1. Decide whether your organisation enables Aria / Sentinel for your workflows.
2. Train staff that Aria and Sentinel are AI systems; do not present AI outputs as human legal advice.
3. Review AI drafts before sending for signature.
4. Inform your own users (internal policies / privacy notices) that Touch2Sign AI features may analyse or generate document-related text when enabled.
5. For public procurement, consider the EU model contractual AI clauses (linked from our clause source catalog).
6. Keep AI disabled where your sector policy forbids third-party AI on document content.

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Evidence you can show auditors

Evidence	Where
Signer AI disclosure + acknowledgement	Signing ceremony · audit events ai_disclosure_expanded / ERSD consent
AI draft marking	HTML source of Aria drafts (data-ai-generated, t2s-ai-generated comment)
DPIA covering AI	/legal/policies/dpia
Sub-processors	/legal/dpa
Internal inventory	Programme hub · EU AI Act Article 50 analysis

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Contact

Questions: legal@touch2sign.com · Privacy: privacy@touch2sign.com

Help centre: /help (article: AI transparency — EU AI Act Article 50)

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Last updated: 2 August 2026