European Union / Regulation (EU) 2024/1689
EU AI Act Article 50: transparency requirements
Understand who must disclose AI use, mark generated content and label deepfakes — and where an evidence record can help.
01 / The requirements
Who owes what
Providers and deployers have different duties. Start with your role, then check the content type and applicable exceptions.
An organisation can be both a provider and a deployer. Map the duties to each system and use case.
02 / Find your duty
Quick decision
Each branch comes from the duties below. Read the paragraph before relying on it; every duty has its own exceptions.
IF YOUprovide a system that generates synthetic audio, images, video or text
Mark outputs in a machine-readable format
§50(2)IF YOUplaced that generating system on the market before 2 Aug 2026
Mark by 2 Dec 2026; the other duties apply from 2 Aug
§50(2)IF YOUpublish AI-generated text on matters of public interest
Disclose it, unless it had editorial review and someone holds editorial responsibility
§50(4)A platform that merely distributes third-party AI content is not a deployer. Light fine-tuning does not make you a provider; putting your own name on the system, substantially modifying it, or changing its intended purpose does.
03 / Dates & transition
Two dates, kept apart
General application of the transparency duties.
Limited transition for Article 50(2) marking by qualifying systems already on the market before 2 August.
It did not move. The Digital Omnibus deferred the high-risk obligations and left Article 50 alone, while rewriting one of its paragraphs, 50(7), and adding a transitional for 50(2) marking.
04 / The duties
Read the duty with its exceptions
The requirement is only the starting point. Read the qualifications alongside the duty, rather than treating a label as the whole answer.
50(1) / Provider
Tell people they are interacting with AI
The obviousness exception depends on the audience and context. General awareness that chatbots exist does not mean someone recognises an AI system in front of them.
▸ Read the provision and qualifications
Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed so that those persons are informed they are interacting with an AI system — unless this is obvious to a reasonably well-informed, observant and circumspect person, taking into account the circumstances and context of use.
50(2) / Provider
Mark generated output, including text
Marking must be effective, interoperable, robust and reliable as far as technically feasible. Text is on the face of the provision.
▸ Read the provision and qualifications
Providers of AI systems generating synthetic audio, image, video or text content shall ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated.
50(4) / Deployer
Disclose deepfakes in context
For evidently artistic, creative or satirical work, the duty is limited to disclosing the content's existence in a way that doesn't hamper the work.
▸ Read the provision and qualifications
Deployers of a system generating or manipulating image, audio or video constituting a deep fake shall disclose that the content has been artificially generated or manipulated.
▸ 50(3) emotion recognition, the 50(4) public-interest text exception, and 50(5) manner and timing
50(3) / DEPLOYER
Inform people exposed to emotion recognition or biometric categorisation systems.
50(4) / PUBLIC-INTEREST TEXT
The duty to disclose AI-generated text published to inform the public on matters of public interest does not apply where the content has undergone human review or editorial control and someone holds editorial responsibility for its publication. Both conditions are cumulative, and the review must be substantive. Any substantive AI edit after editorial sign-off voids the exception. The carve-out disapplies 50(4) only; it does not switch off the provider's 50(2) marking duty.
50(5) / BOTH
Make the information clear and distinguishable, no later than the first interaction or exposure.
05 / Timeline & enforcement
How the dates fit together
The AI Act enters into force. Regulation (EU) 2024/1689, with duties phased across four years.
The Digital Omnibus enters into force. High-risk dates move to 2027 and 2028. Article 50 appears nowhere in the deferral.
Article 50 begins to apply. All four transparency duties. California's SB 942 becomes operative the same day.
The marking transition closes. Pre-existing generating systems must meet the 50(2) marking duty.
Detection interoperability deadline. Under the Code of Practice, signatories route detection through an interoperable method.
WHO ENFORCES
The AI Office for the major frontier-lab assistants and image generators, and AI built into the largest platforms. For everyone else, national market surveillance authorities. An Article 50 breach sits in the tier at up to €15,000,000 or 3% of worldwide annual turnover, whichever is higher. That is not the Act's ceiling.
06 / Optional evidence · where Planisphere fits
Your team takes action. The evidence travels with it.
Your team presents the notice or applies the label. Planisphere seals the event your team reports, as a record anyone can check later.
Your interface tells the person they are interacting with AI, or labels the content.
The event your team reports is sealed when it happens, so a later edit shows.
Paste the receipt into Verify. No account or key.
A record is not a legal conclusion. It doesn't establish that a disclosure was made or that Article 50 is satisfied.
What a receipt proves07 / Questions
The questions that come next
What does Article 50 of the EU AI Act require?+
Providers must address notices when people interact with AI and machine-readable marking of generated content. Deployers must address notices for emotion recognition and biometric categorisation, deepfake disclosures, and disclosures for certain public-interest text. The duties have specific exceptions; the provider and deployer table identifies each paragraph.
When does Article 50 apply?+
Article 50 applies from 2 August 2026. For qualifying systems placed on the market before that date, the Article 50(2) marking obligation applies from 2 December 2026. That extension does not cover the other transparency duties.
Is C2PA enough?+
C2PA alone does not establish compliance. Assess the overall marking and detection solution, the content format, and the applicable qualifications. The final Code and Guidelines reviewed for this page do not name C2PA. Read the full answer.
Does Planisphere certify compliance?+
No. A record can support an evidence process; it is not a legal finding or a certification.
Our system launched last year. Do we have until December?+
For the marking duty only. The new transitional gives providers of synthetic-content systems placed on the market before 2 August 2026 until 2 December 2026 to comply with Article 50(2). Everything else — the interaction disclosure, the deployer duties, the manner-and-timing rule — applies from 2 August. A system that is partly interactive and partly generative gets the extension for its marking and not for its disclosure.
Do we have to go back and mark everything we generated before?+
No. There is no retroactive marking duty for outputs generated before 2 August 2026. But note one asymmetry in the guidance: text generated before that date and published on or after it does need to be labelled.
We signed the Code. Are we covered?+
You are in a much better supervisory position and you have a mitigating factor available at the fining stage. You do not have a presumption of conformity, because none exists for this article, and the Commission has said adherence is not conclusive evidence of compliance. What signing does is change the question from "is your marking adequate?" to "did you adhere?" — which is a question about what you can show over a period.
Does Article 50 apply to us from outside the EU?+
It reaches providers and deployers whose output is used in the Union. The guidance narrows this at the edges — incidental, unforeseeable or unauthorised downstream use should not on its own trigger the obligations — but publishing to the open internet does not obviously fall on the safe side of that line.
How does this compare with California, which starts the same day?+
Different shape entirely. California binds one class of duty holder, prescribes four data elements in the disclosure, requires a public detection tool, and runs a 96-hour licence revocation clock. Article 50 splits duties between provider and deployer, prescribes no data elements, and has no detection-tool duty. California SB 942 disclosure and detection requirements.
08 / Primary sources
Go back to the source
Read the primary text alongside the relevant guidance. Each source has a defined role in this explanation.
Consolidated text dated 27 July 2026. The original and amending regulations in the Official Journal remain authoritative.
Provider and deployer responsibilities, disclosure exceptions and application dates. Used to check the summary on 7 September 2026.
Article 50 itself, the deep-fake definition at Art. 3(60), the penalty tiers at Art. 99.
In force 27 July 2026. Replaces Art. 50(7) and defers the high-risk dates — not Article 50.
Adopted 20 July 2026.
Final text of 10 June 2026.
The Commission's assessment of the Code of Practice.
Harmonised standards work for the AI Act.
09 / Change log
What changed, and when
Layout revision published. This revision does not imply a new review of every source.
Scoped accuracy corrections reviewed.
Summary and two introductory answers checked against Commission guidance.
Related: AI labeling laws compared · California SB 942 · China labelling Measures · India IT Rules · Korea AI Framework Act