EU AI Act Article 50: transparency obligations
Direct answer
Article 50 assigns machine-readable marking of synthetic audio, image, video and text to providers, subject to defined exceptions. Professional deployers must disclose covered deepfakes and certain public-interest text unless the text exception's substantive review or editorial-control and responsibility conditions are met. Duties generally apply from 2 August 2026. Only provider-side marking and detectability for qualifying pre-existing systems have a limited extension to 2 December 2026.
Applies when
- Generating or manipulating image, audio or video that resembles real persons, objects, places or events and would falsely appear authentic.
- Publishing AI-generated text to inform the public on matters of public interest.
Doesn't apply when
- The specific public-interest text disclosure duty does not apply where the text has undergone substantive human review or editorial control and a natural or legal person holds editorial responsibility for publication. Spelling or grammar correction alone is not substantive review.
- Provider-side marking has defined exceptions for assistive standard editing and certain other outputs; those exceptions do not automatically remove a separate deployer disclosure duty.
Disclosure still applies, but its form is adapted
- For a covered deepfake forming part of an evidently artistic, creative, satirical, fictional or analogous work, disclosure is still required. Its form may be adapted so it does not hamper display or enjoyment of the work.
Worked decision
Example
Synthetic voice-over on real product footage
Disclosure recommended
Not automatically a deepfake unless it resembles a real person’s voice or falsely appears authentic; platform policies and client standards usually recommend disclosure.
Next steps
Required action
- Identify provider and deployer roles separately; assess provider marking for synthetic audio, image, video and text.
- Disclose the artificial generation or manipulation clearly and distinguishably.
- For public-interest text, document substantive review or editorial control and who holds editorial responsibility; do not count grammar correction alone.
- Record whether a provider system qualifies for the narrow marking grace period; do not apply it to a publisher's disclosure duty.
- Do not rely on tool-side metadata alone — record the decision yourself.
- Route identifiable-person and consent questions to human review.
Publishing layer
Platform differences
Law, platform and client layers
EU AI Act Article 50(4) requires deployers to disclose realistic AI-generated or manipulated image, audio and video resembling real persons, objects, places or events. Use the platform’s native label and keep your own evidence record.
Evidence
Source
Freshness and accountability
Last verified
Applies from 2026-08-02 · Last reviewed 2026-09-26 · Current
Run this exact scenario
Relevant content, AI-use and platform inputs are preselected. Confirm the remaining facts before relying on the result.
Who is affected
- Marketing teams acting as deployers of generative AI systems in the EU.
- Agencies producing campaign assets with generative components.
- Providers of generative tools whose outputs must be machine-marked.
More scenarios
| Scenario | Outcome | Why |
|---|---|---|
| AI video of a real-looking person endorsing a product | Disclosure required | Article 50(4) deepfake disclosure; also a consent and rights review. |
| AI-generated public-interest article, no substantive human review or editorial control and no accountable editorial owner | Disclosure required | Article 50(4) public-interest text disclosure applies. |
Practical marketing examples
- A campaign video with an AI-generated crowd scene that looks filmed on location — disclose the synthetic scene.
- A cloned voice of a celebrity — do not publish; human review and rights clearance required.
Frequently asked questions
Does Article 50 apply to advertising?
Yes where its triggers are met — realistic synthetic image, audio or video resembling real persons, objects, places or events must be disclosed regardless of whether the use is commercial.
Is a caption enough?
The law requires disclosure that is clear and distinguishable at first exposure. A platform-native label may help, but its presence alone does not prove the legal duty was met. Check what the audience actually sees or hears.
Related pages
Disclara separates binding law, platform policy, client policy, technical provenance and recommended wording. Information on this page is not legal advice. See editorial policy.