FluxyChatFeatures
Art. 50 transparency checklist
What FluxyChat ships for EU AI Act Art. 50 vs what remains your legal duty. Not legal advice.
Art. 50 transparency checklist
This is a product mapping, not a legal opinion. Regulation (EU) 2024/1689 Art. 50 interaction transparency applies from 2 August 2026 (no grace period). Art. 50(2) marking for systems already on the market has a grace window to 2 December 2026. Confirm dates and scope with counsel.
Hosted FluxyChat is beta. Self-host the MIT Cloudflare room layer if you need the code under your own account.
What the software does
| Control | Where |
|---|---|
participantType: human | ai on protocol messages | Worker persist + WebSocket announce |
| Visible IA badge on agent bubbles | @fluxy-chat/ui MessageItem |
| First-contact notice (per project, default on) | Room banner + metadata.firstContactInRoom |
| HMAC-signed machine-readable mark | messages.metadata_json |
| Marks export | GET /admin/eu-ai-act/art-50-marks and console Art. 50 marks |
| Prompt-side “I am an AI” suffix | Runtime policy when disclosure is on |
| Gap assessment | GET /admin/eu-ai-act/assessment |
HMAC is an integrity check for your export file. It is not secrecy and it is not a notified-body seal. Rotate ART50_MARK_SECRET and keep ART50_MARK_SECRET_PREVIOUS until old exports verify. Legal Art. 50 duties stay with the deployer of the agent, not with this HMAC.
What stays on you
- Whether your use is in scope (chatbot vs other AI systems, deployers vs providers)
- Copy for the first-contact notice in your jurisdiction and language
- Training users not to treat agent output as a human operator
- Deepfakes / synthetic media marking beyond in-room text (Art. 50(2) content)
- EU database registration, FRIA, and notified-body work where required
- Accessibility of the widget under the European Accessibility Act (separate from the AI Act; consumer services from 28 June 2025)
Operator steps
- Run D1 migration
0226_art50_message_marks.sql. - Keep Enforce AI disclosure on for customer-facing rooms.
- Keep First-contact notice on unless counsel says the room is out of scope.
- Export marks after a test invoke and store them with your audit pack.
- Read EU AI Act readiness for Art. 9–15 and Annex IV.