SenseDefend

Synthetic-media instruments, by article and effective date

EU AI Act Article 50: what it requires and from when

Article 50 of the EU AI Act sets transparency duties for AI systems that interact with people or generate synthetic content. Providers must mark generated output in a machine-readable format; deployers must disclose deep fakes. The AI Act Explorer records these duties as applying from 2 August 2026 under Article 113. As of 2026-09-12.

Who each duty in the article falls on, and at which momentThe article splits its duties between two roles. A provider builds the system and carries the design-time duties: telling a person they are dealing with an AI system, and marking generated output in a machine-readable format. A deployer publishes or operates and carries the disclosure duties at the moment of exposure. The recorded application date is 2 August 2026, set by Article 113.A providerA deployerWhat they doBuilds or supplies the systemPublishes or operates itWhen the duty bitesAt design timeAt the moment of exposureThe core dutyMark output machine-readablyDisclose a deep fakeRecorded as applying from 2 August 2026, by Article 113
Fig. 1 Almost every misreading of this article comes from applying a provider duty to a deployer, or the other way round. The roles are what the paragraphs are sorted by.
Instrument
Regulation (EU) 2024/1689, Chapter IV, Article 50
Applies from
2 August 2026, per Article 113
Covers
Providers and deployers of AI systems that interact with people, generate synthetic audio, image, video or text, or recognise emotion and biometric categories
Core duty
Inform, mark in machine-readable form, and disclose deep fakes
Source clause
Article 50(1) to 50(7)
Checked
2026-09-12

1Who has to do what, and from which date?

Article 50 splits the duties between two roles. A provider puts the system on the market; a deployer uses it. The marking duty sits with the provider, at the point the output is produced. The disclosure duty sits with the deployer, at the point the output is shown to people. A studio that generates episodes with someone else's model is a deployer for the disclosure duty even though it never touches the marking layer. The role split is set out per paragraph on the duties page.

  • Article 113
    2 August 2026the date Article 50 starts to applyAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(1)
    Providers must design systems so people are told they are dealing with an AI systemunless it is obvious in contextAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(2)
    Providers must mark synthetic audio, image, video and text in a machine-readable formatincluding general-purpose AI systemsAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(3)
    Deployers of emotion recognition or biometric categorisation must inform the people exposed to itAI Act Explorer, Article 50 / recorded 2026-09-12

2What counts as marking, and what is exempt?

Paragraph 2 asks for two different things at once: the output has to be marked in a machine-readable format and it has to be detectable as generated or manipulated. Watermarks, metadata and fingerprinting all sit inside that wording; the paragraph names none of them. The qualifier that follows is doing real work, because it ties the standard to what is technically feasible and to the state of the art rather than to a fixed method.

Providers shall ensure their technical solutions are effective, interoperable, robust and reliable as far as this is technically feasible, taking into account the specificities and limitations of various types of content, the costs of implementation and the generally acknowledged state of the art, as may be reflected in relevant technical standards.

Article 50(2), AI Act Explorer

Two exemptions follow. Editing that is assistive and does not substantially alter the input or its semantics is outside the duty, and so is use authorised by law for detecting or prosecuting crime. Colour grading a clip is the first kind of case; generating the clip is not.

What individual generators publish about the marks they apply is recorded separately, on what generators document about marking.

  • Article 50(2)
    Technical solutions must be effective, interoperable, robust and reliable as far as technically feasiblequalifier on the marking dutyAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(2)
    Machine-readable marking does not apply to assistive standard editing that does not substantially alter the inputsecond exemptionAI Act Explorer, Article 50 / recorded 2026-09-12

3Does a drama series count as a deep fake?

Paragraph 4 puts the disclosure duty on the deployer, then narrows it for creative work. The narrowing is not an exemption: the obligation becomes a duty to disclose that such generated content exists, in a manner that does not hamper the display or enjoyment of the work. An end-card or a description line is the shape that wording points at; a caption burnt across the middle of every shot is not required by it.

Where the content forms part of an evidently artistic, creative, satirical, fictional or analogous work or programme, the transparency obligations set out in this paragraph are limited to disclosure of the existence of such generated or manipulated content in an appropriate manner that does not hamper the display or enjoyment of the work.

Article 50(4), AI Act Explorer
  • Article 50(4)
    Deployers must disclose image, audio or video content that is a deep fakefirst subparagraphAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(4)
    For evidently artistic, creative, satirical or fictional work the duty narrows to disclosing that such content exists, in a way that does not hamper enjoyment of the workfirst subparagraphAI Act Explorer, Article 50 / recorded 2026-09-12

4What about AI-written text?

The second subparagraph of paragraph 4 reaches text published to inform the public on matters of public interest, and then lifts the duty where the text went through human review or editorial control and a person carries editorial responsibility for it. Marketing copy and fiction are not what that subparagraph is aimed at.

  • Article 50(4)
    Deployers must disclose AI-generated text published to inform the public on matters of public interestsecond subparagraphAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(4)
    The text duty falls away where the output had human review or editorial control and a person holds editorial responsibilitysecond subparagraphAI Act Explorer, Article 50 / recorded 2026-09-12

5When does the information have to reach the viewer?

Paragraph 5 fixes the timing rather than the format: clearly and distinguishably, at the latest at the first interaction or exposure, and conforming to accessibility requirements. Paragraph 7 leaves the method to codes of practice that the Commission is to encourage, with an implementing act held in reserve if a code turns out to be inadequate.

  • Article 50(5)
    The information must be given clearly and distinguishably at the latest at the first interaction or exposureand must meet accessibility requirementsAI Act Explorer, Article 50 / recorded 2026-09-12
  • Article 50(7)
    The Commission is to encourage codes of practice on detection, marking and labelling, and may adopt an implementing act if a code is inadequateprocedure in Article 98(2)AI Act Explorer, Article 50 / recorded 2026-09-12
  • recitals the Explorer links to Article 50
    Recitals 120, 132, 133, 134, 135, 136 and 137AI Act Explorer, Article 50 / recorded 2026-09-12
  • status marker shown at the end of the article text
    The Explorer flags the text of Article 50 as amendedAI Act Explorer, Article 50 / recorded 2026-09-12

6Sources

Article text and the application date on this page are recorded from the AI Act Explorer entry for Article 50, maintained by the Future of Life Institute, checked 2026-09-12. Each fact row above carries the same link and its own check date.