Practical guide · Article 50 of the AI Act
Article 50 has applied since 2 August 2026, but it does not require a visible label on every advert that used AI. This guide separates provider and deployer duties, explains deepfake disclosure and turns traceability into a manageable production workflow.
Reviewed 23 August 2026 · General information, not legal advice
In one sentence: providers of generative AI systems must enable machine-readable marking of outputs; deployers must disclose deepfakes and certain AI-generated or manipulated text published to inform the public on matters of public interest, unless it has undergone human review or editorial control and a person holds editorial responsibility for publication. Our visible disclosure, marking-preservation and documentation workflow is a voluntary production standard, not a universal legal package for every advert.
What the law says
Duties depend on the organisation’s role and the specific content, not on whether the campaign used an AI tool.
Must design generative systems so outputs carry effective, reliable, robust, interoperable machine-readable marking, subject to the stated editing and contextual exceptions.
Must clearly disclose deepfakes and certain AI-generated or manipulated text published to inform the public on matters of public interest, unless it has undergone human review or editorial control and a person holds editorial responsibility for publication. This is not a blanket rule for every advert.
Providers of systems that interact directly with people must inform them they are interacting with AI unless that is obvious. This chatbot rule is separate from audiovisual disclosure.
Standard assistive editing may fall outside provider marking. Film backgrounds, VFX and technical pre/post-production are not automatically deepfakes: resemblance, message, deployment context and audience expectations matter.
First decision
Ask who is using which system, what the piece depicts and whether it could falsely appear authentic or truthful in its deployment context.
| Case | Article 50 treatment | Reason |
|---|---|---|
| Deepfake of an existing person, object, place, entity or event | Clear deployer disclosure | It must falsely appear authentic or truthful; context and audience expectations count. |
| AI-generated or manipulated text published to inform the public on matters of public interest | Disclosure, subject to the editorial exception | The exception requires human review or editorial control and a person holding editorial responsibility for publication. |
| Clearly fictional or creative advertising | Case by case; no universal visible label | Any applicable disclosure for artistic or fictional work may avoid hampering enjoyment. |
| Standard colour, audio clean-up or assistive editing | Usually outside provider marking | Where it does not substantially alter input data or meaning. |
| Film backgrounds, set extensions, VFX or technical post | Contextual assessment | Commission guidance says these are unlikely to deceive where authenticity is not expected. |
| Content generated before 2 August 2026 | No retroactive labelling duty | Voluntary transparency is encouraged. |
Where disclosure applies or is chosen
Article 50 requires applicable information to be clear, distinguishable and accessible; it does not prescribe one sentence for every medium. These are production recommendations, not fixed legal formulas.
| Channel | Recommended practice | Check |
|---|---|---|
| TV and VOD | Clear disclosure by first exposure; for creative work, integrate it without hampering the experience | Legibility, duration and delivery notes |
| Social platforms | Use platform declarations and add visible disclosure where the assessment requires it | Review each platform’s separate policies |
| Web, display and DOOH | Perceivable disclosure in the creative or immediate context when applicable | Readable at every size and distance |
| Audio | Audible disclosure when the relevant case requires it | First exposure and clarity |
Provider duty
Article 50(2) addresses the provider of the generative system. It should not be confused with a visible deployer disclosure.
Outputs marked and detectable as AI-generated or manipulated through effective, reliable, robust, interoperable and technically feasible solutions.
Inventory tools, check what marking reaches the file and seek to preserve it through editing and export. This is technical preparation, not legal certification.
A limited grace period to 2 December 2026 covers certain systems placed on the market before 2 August, and only the marking and detection duty in Article 50(2).
Second decision
Brand, agency and production company are not automatic legal categories under Article 50.
Develops or has the system developed and places it on the market or puts it into service under its name.
Uses the system under its authority in a professional activity and assesses any disclosure duty.
Can allocate technical tasks, approvals and archives by contract, without changing the statutory role by wording alone.
Our voluntary standard
These are production controls, not six universal legal duties.
Pieces, systems, generation dates, provider and deployer.
Deepfake, public-interest text, assistive editing, fiction or VFX.
Clear channel format or voluntary brand transparency.
Check and preserve available machine-readable marking.
Tools, sources, licences, consents and decisions.
Masters, versions and points needing legal validation.
Applied review
Tell us about the piece, systems and channels. We can run a technical applicability review or a team workshop and define scope, deliverables and schedule after reviewing the context.
Request a reviewNeed production support?
We review or produce the piece, check available marking, prepare disclosure where applicable and document rights and versions. We do not guarantee legal compliance and coordinate with your counsel where needed.
See the technical preparation serviceFrequently asked questions
Official sources: Regulation (EU) 2024/1689; Commission Guidelines; Commission FAQ; Quick Facts; and Regulation (EU) 2026/1744. General information, not legal advice. Reviewed 23 August 2026.