Do we still need a lawyer?

Usually, yes. Counsel interprets and accepts legal positions. The sprint removes expensive discovery work by giving counsel a structured system map, evidence register, draft wording and precise questions.

Is this only for chatbots?

No. The scope covers directly interactive AI, synthetic-content marking, emotion or biometric disclosure, deepfakes and public-interest text where relevant.

What starts the seven-day clock?

Kickoff plus the minimum input pack: system list, owners, interfaces, current notices, relevant vendor material and access to evidence. Missing client inputs pause the clock.

What if we have more than five systems?

The fixed sprint covers a maximum of five. We can select the highest-priority systems or prepare a separate multi-system scope without pretending the same price covers both.

Do you implement disclosure changes?

Not inside the fixed price. The pack includes implementation-ready UX copy and event specifications. Production implementation can be scoped separately.

What if our system may be high-risk?

The sprint can flag that boundary and package evidence, but it does not perform a high-risk conformity assessment. We route that work to a specialist scope.

Does the pack prove a legal outcome?

No. It is an evidence baseline and technical implementation specification prepared for legal review. It does not replace a legal opinion or authority decision.

Can procurement review the sample first?

Yes. The visible preview shows core artefacts, and the complete anonymised EN/PL PDF is available through a private 24-hour link sent to a business email.

Article 50 transparency duties apply from 2 August 2026.

Article 50 Evidence Sprint

Turn Article 50 obligations into evidence and implementation tasks in 7 business days

For one legal entity and up to 5 AI systems. You receive a decision-ready evidence baseline, disclosure specifications and a prioritised backlog prepared for legal review.

1 entity · typically 2–3, maximum 5 systems · EN + PL · 7 business days

Representative sample · no client data

ARTICLE 50 / EVIDENCE REGISTER

systems

triggers

evidence items

A50-01

A50-02

A50-03

A50-04

System-by-system proof, ownership and next action

60-second orientation

Could Article 50 be triggered by your systems?

Select what your systems do. The result is an operational routing aid, not a legal determination.

Four transparency triggers, mapped to accountable evidence

The final Commission guidelines published on 20 July 2026 distinguish provider and deployer duties. We map the relevant trigger, responsible role and evidence for each system.

01Provider

Direct interaction

Disclosure that a person is interacting with AI, assessed against the four cumulative criteria and the restrictive obvious-AI exception.

02Provider

Synthetic output

Machine-readable marking for AI-generated or manipulated image, audio, video and text, including the standard-editing and B2B/industrial conditions.

03Deployer

Emotion / biometrics

Disclosure where emotion-recognition or biometric-categorisation systems are used, with specialist scoping where engineering falls outside the sprint.

04Deployer

Deepfake / public-interest text

Clear disclosure for deepfakes and public-interest text, including the human-review and editorial-control test.

See the shape of the deliverable before you buy

The preview is filled with a fictional system landscape, not fictional results. It shows the level of specificity delivered in the full pack.

Full table of contents

01Executive decision memo
02AI system inventory and role matrix
03Trigger and exception assessment
04System evidence cards
05As-is / to-be disclosure map
06PL + EN disclosure copy for legal review
07Vendor and dependency map
08Audit-trail event specification
09Accessibility check
10Evidence register, assumptions and backlog

TRIGGER MATRIX / SAMPLE

System	Role	Trigger	Evidence state
Customer support agent	Deployer	Direct interaction	Gap: first-interaction notice
Product-image workflow	Provider	Synthetic output	Verify metadata marking
Editorial assistant	Deployer	Public-interest text	Human-review record present

SYSTEM CARD / A50-03

PROPOSED FIRST-INTERACTION DISCLOSURE

You are interacting with an AI assistant. You can ask for a person at any time.

OWNER

Product Ops

STATUS

Gap open

BACKLOG EXCERPT

P0 · Add disclosure before the first AI response
P0 · Log disclosure version and timestamp
P1 · Add accessible text alternative to the audio notice

Download the complete EN / PL sample

A private 24-hour link is sent to a business email. The PDFs remain outside search indexes and contain no client data.

A faster management decision, not another folder of observations

BEFORE

No named owner per trigger
Vendor claims mixed with internal evidence
Legal questions without system context
No implementation sequence

AFTER

Roles and triggers mapped per system
Evidence linked to owner and location
Questions packaged for counsel
Prioritised technical backlog

AROG + legal counsel: clear division of work

AROG AI

Maps systems, roles, vendors and interfaces
Specifies disclosures, events and evidence
Builds the gap backlog and executive handoff

LEGAL COUNSEL

Interprets the law for your facts
Approves wording and legal positions
Advises on wider regulatory obligations

A fixed price because the boundary is explicit

One system means one AI surface or pipeline with a distinct Article 50 trigger profile. Multiple interfaces with the same behaviour may be grouped only when evidence and ownership are genuinely shared.

Included

One legal entity
Typically 2–3, maximum 5 AI systems
Provider / deployer role map
Four Article 50 trigger checks
Direct-interaction criteria and relevant exceptions
PL + EN disclosure drafts
Accessibility and evidence check
One consolidated revision round

Outside the fixed price

Legal opinion or legal sign-off
High-risk conformity assessment or DPIA
Production code implementation
Provider-side watermarking or C2PA implementation
Biometric or emotion-recognition engineering
Multi-entity group assessment

Day 0–7: a controlled evidence workflow

Scope lock

Kickoff, minimum input pack and named owners. The clock starts only when required access and artefacts are available.

1–2

Inventory

System boundaries, roles, vendors, content types, interfaces and current notices.

3–4

Trigger mapping

Trigger, exception, evidence and gap assessment with assumptions clearly marked.

5–6

Implementation specification

Disclosure copy, event specification, accessibility check and prioritised backlog.

Executive handoff

Decision memo, evidence register, legal-review questions and consolidated walkthrough.

Client delays stop the clock. One revision round means one consolidated list of comments delivered within 3 business days.

A serious baseline without a large-firm entry ticket

The fixed price covers the defined evidence scope. It does not hide implementation work inside ambiguous wording.

Article 50 Evidence Sprint

€2,290 excl. VAT

50% at kickoff · 50% on delivery · reverse charge where applicable

1 entity · typically 2–3, maximum 5 systems · EN + PL · 7 business days

Delivery assurance covers the agreed table of contents and fixed scope. No legal outcome is promised.

Clearly priced add-ons

Joint review workshop with your counsel€450

Implementation support blockfrom €900

Additional entity or more than 5 systemsseparate scope

Built on primary sources and an inspectable method

Updated 2026-07-20 against the final European Commission Article 50 guidelines and official Q&A. The pack separates observed evidence, assumptions, technical recommendations and questions reserved for legal interpretation.

Adam Rogacki

Founder, AROG AI · method owner

PRIMARY SOURCES · UPDATED 2026-07-20

European Commission · Final Article 50 guidelines European Commission · Official Article 50 Q&A EUR-Lex · Regulation (EU) 2024/1689

Procurement-ready boundaries

Contracting

The invoicing entity, VAT treatment, payment terms and exact delivery table are disclosed in the SOW before acceptance.

Data handling

The sprint is designed around system artefacts and evidence, not production personal data. Retention, access and deletion are fixed in the SOW/DPA.

Confidentiality

Access is limited to the named delivery team. Subprocessors and transfer details are supplied before kickoff where applicable.

Ownership

Client data remains the client's. The client receives the delivered pack and an internal-use right to working templates; pre-existing AROG methods remain AROG IP.

Independence

If AROG built a reviewed system, that relationship is disclosed. The work is not described as independent assurance.

Liability boundary

The SOW states confidentiality, liability cap and the absence of legal advice. Delivery is measured against the agreed scope and table of contents.