BRUSSELS – The Business Software Alliance (BSA) called on the European Commission to revise the draft Code of Practice on transparency requirements under Article 50 of the EU AI Act to ensure it remains faithful to the scope of the law and workable in practice.

In its recommendations, BSA highlights three priorities:

• Respect the scope of the AI Act. The Code should not expand obligations beyond Article 50 or shift responsibilities to AI model providers where the Act does not assign them.
• Ensure proportionality and technical feasibility. Transparency measures must reflect the state of the art, apply only where technically feasible, and follow a risk-based approach—particularly for low-risk Business-to-Business (B2B) uses.
• Clarify role allocation along the AI value chain. Obligations should be clearly assigned to providers and deployers of AI systems, consistent with the structure of the Act.

BSA also stresses the need for policy coherence. The Code must align with the Commission’s forthcoming Transparency Guidelines and the ongoing AI Digital Omnibus proposal, especially where measures relate to Article 50. A dedicated stakeholder consultation will be essential to ensure consistency. The Commission should also provide clear guidance on how transparency rules apply to agentic AI and voice assistants.

“A well-calibrated transparency framework can strengthen trust while supporting Europe’s AI competitiveness,” Hadrien Valembois, Director, Policy – EMEA, said. “The Code should facilitate compliance with the AI Act, not expand it.”