Practical guide / Generative AI
Article 50: how to mark and disclose AI-generated content
An invisible watermark, content credentials and a public disclosure serve different purposes. Understanding them helps you prepare a delivery without assuming every generated file already includes everything required.
Technical marking and public disclosure are different
Article 50 of the EU AI Act assigns duties according to each participant’s role. Providers face machine-readable marking requirements in specified circumstances; deployers have disclosure duties for certain content, including deepfakes.
The Commission’s Code of Practice provides a voluntary route to support compliance. Signing it does not establish that every file or publication is compliant.
Different content requires different assessment
The article includes conditions and exceptions. Evidently artistic or fictional works have an adapted disclosure regime. For text on matters of public interest, human review or editorial control with an accountable publisher also matters.
Start by identifying the content, its use and each participant’s obligations.
Timing varies too: certain systems placed on the market before 2 August 2026 have a transition until 2 December for Article 50(2) marking. See our AI Act timetable for context.
What each signal provides
| Signal | Purpose | What not to assume |
|---|---|---|
| Technical watermark | Help detect synthetic origin | That it survives every transformation |
| C2PA credentials | Verify signed provenance information | That they prove the depicted scene is true |
| Visible or audible disclosure | Inform the audience | That it replaces all technical requirements |
C2PA supports verification of provenance information linked to a file. Metadata can be lost during some transformations, and missing credentials do not establish that content is fake. Credentials are not a copyright register either.
Prepare the delivery in four steps
- Identify generated or manipulated elements and retain the originals.
- Check which signals the tool actually includes.
- Test the export and publishing channel: conversion may alter available information.
- Agree who checks disclosure, where it appears and who approves the published version.
A production note can record the model, date, human edits and reference files. It helps the team coordinate but does not replace information that must reach the audience.
For identifiable people, review permissions as well. Authorship and third-party rights require a separate assessment from transparency.
To prepare that delivery with its documentation, tell us which pieces carry credentials and where they are published.
Sources
Checked on September 20, 2026