Comply with AI Act Article 50 transparency duties: AI interaction disclosure, machine-readable marking of synthetic content, and deepfake disclosure

Documented steps

1. Diary the date: Article 50 applies from 2 August 2026 and was not postponed by the AI Omnibus. Commission FAQ: https://digital-strategy.ec.europa.eu/en/faqs/navigating-ai-act
2. Provider duty under Article 50(1): for systems intended to interact directly with natural persons, ensure people are informed they are interacting with an AI system, clearly and distinguishably, at the latest at the time of the first interaction. The exception is where this is obvious to a reasonably well-informed, observant and circumspect person, and for systems authorised by law to detect, prevent or investigate criminal offences unless publicly available for crime reporting.
3. Provider duty under Article 50(2): for systems generating synthetic audio, image, video or text, mark outputs in a machine-readable format and make them detectable as artificially generated or manipulated. Solutions must be effective, interoperable, robust and reliable as far as technically feasible.
4. Apply the marking exemptions rather than marking everything. Per the Commission's Article 50 FAQ these include short sequences of numbers, symbols or letters; source code; outputs intended exclusively for machine-to-machine communication with no human exposure; outputs used only in closed development or production environments unless they are the final output; and systems performing an assistive function for standard editing. Read the current list: https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act
5. Use the transitional window correctly: generative AI systems placed on the market before 2 August 2026 must comply with the marking obligation as from 2 December 2026. Content generated before 2 August 2026 does not require retroactive labelling, although the Commission encourages it where feasible.
6. Deployer duty under Article 50(3): where you operate an emotion recognition or biometric categorisation system, inform the exposed natural persons of its operation and process the personal data in line with data protection law.
7. Deployer duty under Article 50(4): disclose that image, audio or video content constituting a deepfake is artificially generated or manipulated, at the latest at the time of first exposure. For content that is evidently part of an artistic, creative, satirical or fictional work, the disclosure is limited so as not to hamper the display or enjoyment of the work. AI-generated or manipulated text published to inform the public on matters of public interest must be disclosed unless it has undergone human review or editorial control with a natural or legal person holding editorial responsibility.
8. Choose the marking technology yourself. The Commission does not mandate a specific watermarking standard; the requirement is a performance standard. Select a method and be able to evidence why it is effective, robust, reliable and interoperable for your content types.
9. Optionally adopt the Commission's EU icon set for human-facing labelling of deepfakes and AI-generated public-interest text: https://digital-strategy.ec.europa.eu/en/policies/eu-icons-labelling-ai-generated-content . Icon use is optional and does not satisfy the separate machine-readable marking duty.
10. Consider the Code of Practice on Transparency of AI-generated Content as a voluntary demonstration route: https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content
11. Meet the accessibility requirement: disclosures must be clear, distinguishable and provided in an accessible manner.
12. Size the exposure: Article 50 breaches sit in the Article 99(4) tier, up to EUR 15 000 000 or 3% of total worldwide annual turnover for the preceding financial year, whichever is higher. Text: https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-99