Article 50 assigns different duties to the organization providing an AI system and the organization using it. A single “AI” badge does not answer every requirement.
Begin with the duty, not the badge
Article 50 separates direct-interaction notice, provider-side machine-readable output marking, notice for emotion recognition/biometric categorisation, and deployer disclosure of deepfakes or certain public-interest text. The text-publication exception requires substantive human review or editorial control and editorial responsibility. It is not a blanket exception for synthetic images.
The Commission FAQ states August 2 applicability, while describing a limited transition until December 2, 2026 for Article 50(2) marking/detection by providers of systems placed on the market before August 2. That is not a general delay for visible disclosure. It also says earlier content need not be labelled retroactively.
Follow one asset through the publication chain
Imagine an organization generating a realistic synthetic interview video, editing it and publishing several crops. Its inventory should identify the system provider, the organization publishing it, the original asset and each derivative. A provider’s embedded mark and a viewer-facing disclosure serve different audiences; preserving one does not establish that the other is present.
As an engineering check, inspect the final page and the redistributed file separately. Does a viewer encounter the notice at first exposure? Do transformations preserve the intended machine-readable information? These questions reveal missing handoffs without assuming that one file format or icon alone certifies compliance.
Keep the review record meaningful
For public-interest text, record who can approve, alter or reject the substance and who takes editorial responsibility. An automated grammar pass is not human review. The voluntary code of practice offers an implementation framework; it does not replace the regulation.
This overview helps map a publishing workflow. For a specific legal determination, assess the actual system, use and applicable exceptions with qualified advice rather than treating the diagram as a compliance certificate.
September 8: verify official Article 50 guidance, add the limited December marking transition and the editorial-review exception; separate provider marking from visible disclosure.