Classification of Eye-Able's AI Functions under Art. 50 of the AI Act
Which functions are relevant for labeling and which are not?
Art. 50 para. 2 of the AI Act exempts systems that perform an assisting function for standard processing or that do not substantially alter the input data or its semantics. This article classifies Eye-Able's individual AI-supported functions accordingly.
Translation and read-aloud function
A meaning-preserving translation with Eye-Able Translate, as well as the unaltered reading aloud (text-to-speech), leave the semantics of the source text you are responsible for untouched. According to the wording and large parts of the commentary literature, this constitutes assisting standard processing that is not subject to the labeling obligation of para. 2.
Simplification and AI-generated alternative text
For Eye-Able Plain Language and for AI-generated alternative text (AI scans), the boundary is narrower, since more substantial content processing takes place. Eye-Able treats such output as a precaution as potentially relevant for labeling.
Eye-Able Ally
Insofar as the assistant interacts directly with users, Eye-Able ensures the disclosure obligation under para. 1 — that is, clear labeling as an AI assistant.
Open question of interpretation for translations
The wording of the law suggests treating meaning-preserving translations as standard processing exempt from labeling. The European Commission's 2026 guidelines, by contrast, list AI-generated translations as generally relevant for labeling. These guidelines are not legally binding but are significant for supervisory practice. To give you certainty regardless of how this question is resolved, Eye-Able implements the provider-side machine-readable labeling under Art. 50 para. 2, insofar as the models used support it, and within the applicable deadlines.
Further articles
In the following article, you’ll find further information on similar topics:
- The EU AI Act and the Eye-Able software solutions
- Labeling obligations under Art. 50 of the AI Act for deployers
If you have any further questions, our team will be happy to help! In the following article, you’ll find out how to get in touch with us: