AI Act Article 50: EU Rules on Labelling Synthetic Content from 2 August 2026
Article 50 of Regulation (EU) 2024/1689, the EU AI Act, has applied since 2 August 2026: providers and deployers of AI systems must make it clear when image, audio or video content, and certain published text, have been generated or manipulated by artificial intelligence, with a reinforced disclosure duty for deepfakes. Regulation (EU) 2026/1744 (the Digital Omnibus), in force since 27 July 2026, gives a grace period until 2 December 2026 only for the machine-readable marking of Article 50(2), for systems placed on the market before 2 August 2026. The rule introduces a single European standard for synthetic content transparency, ending a fragmented landscape in which voluntary watermarking and provider-specific labels lived side by side with unlabelled outputs. For AI compliance officers, media leads and editorial teams using generative AI, the date still open is 2 December, and only for providers of systems already on the market: their machine-readable marking has to be ready by then. Deployer duties, such as disclosing deepfakes, have applied since 2 August. Labelling what is synthetic is only half of the problem: the other half is proving that an original photo, video or document is authentic and untouched. That second half is where TrueScreen works: it counters deepfakes and manipulated data by certifying originals with a forensic methodology at the moment they are acquired, so that their authenticity can be demonstrated instead of argued.
What Article 50 of the AI Act requires
Article 50 sits inside the transparency obligations of the AI Act and imposes duties on both providers (who develop or place AI systems on the EU market) and deployers (who use them professionally). The common principle: users and recipients of content must know when they are interacting with AI, or consuming output generated or altered by AI.
Clear labelling for AI-generated audio, video, image and text content
Providers of AI systems that generate synthetic audio, image, video or text must ensure that outputs are marked in a machine-readable format and detectable as artificially generated or manipulated. Solutions must be technically feasible, effective, interoperable and robust considering the state of the art. In parallel, deployers of AI systems that generate or manipulate text published to inform the public on matters of public interest must disclose that the text has been artificially produced, unless a human has reviewed and assumed editorial responsibility. The logic is consistent: whenever content reaches the public, the public must know its origin. For newsrooms and corporate communications teams, this translates into explicit labelling rules inside content management systems, editorial checklists and publishing templates.
Deepfakes: reinforced disclosure obligation
Deepfakes receive a dedicated paragraph. Deployers of AI systems that generate or manipulate image, audio or video content constituting a deepfake must disclose that the content has been artificially generated or manipulated. The disclosure must be clear and distinguishable, no later than at the time of first interaction or exposure. This goes beyond a generic watermark: it is a duty of active communication toward the audience. The rule applies regardless of the artistic quality of the output and regardless of whether the deepfake is benign or malicious. Reference: Regulation (EU) 2024/1689.
Code of Practice from the Commission
Article 50 is complemented by Commission guidelines and by a Code of Practice on the marking and labelling of AI-generated content, prepared with the support of the AI Office. The Code translates the legal obligations into operational requirements on marking techniques, metadata, detectors and cross-platform interoperability. Compliance teams should follow the official texts on digital-strategy.ec.europa.eu and align internal policies with the versions in force.
Who is obligated
The scope of Article 50 is wide and covers the full value chain of synthetic content, from model providers to enterprises that integrate GenAI into their daily operations.
Providers of general-purpose AI systems (GPAI)
Providers of GPAI systems capable of generating synthetic content must embed marking mechanisms at the model or system level, so that outputs carry machine-readable signals identifying them as AI-generated. The marking must survive reasonable post-processing (re-encoding, format conversion) and must be documented in technical documentation made available to downstream deployers. In practice, vendors of foundation models and generative services need to expose, through API and product documentation, how their marking works and how deployers can keep it intact.
Deployers: enterprises and newsrooms using GenAI
Any organisation that uses generative AI to produce content for the public is a deployer. This includes media companies publishing AI-assisted articles, marketing departments generating product images or videos, legal and compliance teams drafting synthetic summaries, and public administrations using chatbots on matters of public interest. Each of them must ensure that outputs are labelled and, where deepfakes are involved, disclosed to the audience. Internal policies need to cover tooling selection, editorial workflows, disclosure templates and staff training.
Platforms and sharing services
Online platforms and sharing services remain governed by the Digital Services Act, but Article 50 creates a stronger substrate of labelled content that platforms can surface to users. Where platforms integrate generative features, they act as both providers and deployers and must honour both roles. Expect platform-level UI changes: badges, disclosure banners and labels on synthetic media are likely to become the default. For a broader view on how these duties combine with the rest of the regulation, see our analysis of AI Act transparency obligations.
Exceptions and sanctions regime
Transparency duties are not absolute. Article 50 foresees targeted exceptions and a sanctions framework proportionate to the scale of the operator.
Obviously artistic, satirical, or fictional content
When synthetic content is part of an evidently creative, satirical, fictional or analogous work, the disclosure duty is adapted so that it does not hinder the enjoyment of the work itself. The disclosure must still be present, but in a form and place that does not impair creative freedom. The exception is narrow: it applies to content whose artistic nature is obvious to a reasonable viewer, not to deepfakes disguised as news or testimonial.
Sanctions up to 3% of global annual turnover
Non-compliance with Article 50 falls under the general sanctions framework of the AI Act. Breaches of transparency obligations can reach fines of up to EUR 15 million or up to 3% of the total worldwide annual turnover for the preceding financial year, whichever is higher. National authorities, coordinated with the AI Office, enforce sanctions. The financial exposure is material enough to justify board-level attention, formal risk assessments and dedicated budget for compliance tooling.
Ex-post transparency and ex-ante verifiability: the role of TrueScreen
Article 50 addresses synthetic content after it has been generated: it tells the audience that what they see or read is artificial. This is necessary, but it does not prove that an original photo, video or document is authentic. The mirror-image question becomes urgent: how do we certify that a real asset has not been altered and that it was captured at a specific time and place?
TrueScreen does not rely on spotting a fake after the fact. It certifies original content at the source: photos, videos and documents acquired with the TrueScreen App, the Forensic Browser, the Browser Extension or the API go through a forensic acquisition that verifies and documents each step in a technical report, and the certification closes with a qualified electronic seal and a qualified timestamp. When the content already exists and cannot be protected at the source, TrueScreen integrates deepfake detection into its process together with other checks. The resulting package has full legal and evidentiary value and can be verified independently at any later moment.
For a compliance strategy aligned with Article 50, the combination is straightforward. On one side, deployers label every AI-generated output and disclose deepfakes. On the other side, teams that need authenticity on originals (legal evidence, inspections, journalism, regulatory filings, insurance claims) adopt TrueScreen to certify the asset at the source, so that any change after capture can be detected, the same procedure described step by step for certifying a photo at the source. Labelling the synthetic and certifying the original are complementary layers: together, they protect against both undisclosed manipulation and later tampering. Certifying originals does not replace the marking duty, and it does not make an organisation compliant with the AI Act on its own.
FAQ
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TrueScreen editorial team
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This section is edited by the TrueScreen editorial team, which brings together expertise in digital forensics, the law of digital evidence and regulatory compliance. Every article is checked against primary sources: legislation, published rulings, technical standards and official documentation, always cited in the text.
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