Official-source-backed technical resource

Record a proposed transparency exception decision

Document the facts, source version and qualified reasoning behind a proposed exception. Includes a free implementation worksheet.

Short answer

Document the facts, source version and qualified reasoning behind a proposed exception. Keep uncertainty and reassessment triggers visible rather than storing only an exempt checkbox.

Download the blank working record (.md)

When to use this guide

A product team marks a feature exempt because another product uses similar wording, without assessing its own audience or output.

This is a fictional implementation scenario. The procedure below is Article 50 Hub's suggested working method, not a prescribed legal form, a customer result or a claim that every step is an additional statutory requirement.

Review procedure

  1. Identify the specific obligation and exception being considered.

  2. Record the system facts and official source version used in the assessment.

  3. Have the responsible qualified reviewer explain the reasoning and unresolved questions.

  4. Define changes that require reassessment and connect the decision to the deployed feature.

What the example review finds

  • The decision relies on a competitor's behavior.

  • The recorded exception does not identify the relevant obligation.

Keep these example observations separate from your own results. An unknown or untested state should stay open until the relevant evidence has been inspected.

Fields for your working record

  • Obligation

  • Proposed exception

  • System facts

  • Reviewer reasoning

  • Reassessment trigger

Use the downloadable blank worksheet linked on this page to connect the observed behavior with the deployed system. Add a reviewer, date, evidence reference, unresolved questions and a next action. The worksheet is editable locally and does not upload your records to Article 50 Hub.

Completion and handoff

Close the task only for the scope actually reviewed. Preserve the result that another authorized reviewer can reproduce, identify the owner of remaining work, and record a retest when the implementation changes. A completed worksheet is not a substitute for the underlying evidence.

Decision boundary

The worksheet does not grant an exception or substitute for legal assessment of the actual facts.

The official references below provide legal or technical context. Resolve applicability and exception questions with the responsible qualified reviewer; use the product's tools to organize implementation work within that assessment.

Official sources

  1. EU AI Act — legal text and contextEUR-Lex
  2. Commission FAQ — transparency obligations and scopeEuropean Commission
  3. Article 50 Service Desk — read with its amendment notice and current Commission guidanceEuropean Commission

Last reviewed: 2026-09-23. This is technical implementation information, not legal advice.

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