AI content marking has two different duties
Article 50 does not impose one blanket visible label on every AI-assisted asset. Providers of generative AI have a machine-readable marking duty, while deployers have visible disclosure duties for deepfakes and certain public-interest text.
Who this applies to
- Providers of AI systems that generate synthetic audio, image, video or text
- Deployers publishing deepfake audio, images or video
- Deployers publishing AI-generated or manipulated text to inform the public on matters of public interest
- Teams publishing synthetic media that realistically depicts people, places, entities or events
What the regulation requires
Article 50(2) requires providers of generative AI systems to mark outputs in a machine-readable format and make them detectable as artificially generated or manipulated, where technically feasible. Article 50(4) separately requires deployers to disclose deepfake content and AI-generated or manipulated public-interest text. The text duty has an exception where human review or editorial control exists and a person holds editorial responsibility.
Implementation steps
- 1Inventory synthetic audio, image, video and text by system, publishing channel and audience.
- 2Separate the provider's machine-readable marking duty from the deployer's visible-disclosure duty.
- 3Use the Commission's published code-of-practice materials and icons where they fit your case.
- 4Record any human-review or editorial-responsibility basis you rely on for public-interest text.
Common implementation gaps
- Treating the machine-readable provider duty and visible deployer duty as the same obligation.
- Calling every AI-assisted marketing image a deepfake without checking the statutory definition.
- Assuming a platform watermark always satisfies the information, accessibility and timing requirements.
The assessment
Company assessment
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What you receive
- •AI inventory and system classifications
- •Article 50 duties by touchpoint
- •Recommended notice wording and placement
- •Evidence and documentation gaps
- •Prioritised actions and deadlines
- •Specialist review and follow-up questions
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