EU AI Act Article 50: what you must label, by when, and how

A practical guide for companies that create or publish AI-generated images, video, audio or text in the EU. Updated October 2026, including the changes made by Regulation (EU) 2026/1744 (the “Digital Omnibus on AI”).

In short

1. Who has to do what

Article 50 splits the duties between two roles. Many companies are both.

You areYour dutyWhere
Provider — you build or sell an AI system that generates images, audio, video or textMark every output in a machine-readable format so that it is detectable as AI-generated or manipulated.Art. 50(2)
Deployer — you use AI to create image, audio or video content that is a deep fakeDisclose that the content was artificially generated or manipulated.Art. 50(4)
Deployer — you publish AI-generated text to inform the public on matters of public interestDisclose that the text was artificially generated, unless it went through human review and someone holds editorial responsibility.Art. 50(4)

The core sentence for providers:

…shall ensure that the outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated.Regulation (EU) 2024/1689, Article 50(2)

The marking has to work in practice, not just exist on paper: providers must make their technical solutions effective, interoperable, robust and reliable as far as technically feasible. Purely assistive editing that does not substantially alter the input is exempt.

2. The deadlines

DateWhat happensSource
2 August 2026Article 50 applies in full to new AI systems and to deployers.Art. 113
2 December 2026Providers whose generative AI systems were placed on the market before 2 August 2026 must comply with the marking duty of Art. 50(2).Art. 111(4), added by Reg. (EU) 2026/1744

The December date is a grace period for existing systems only. It does not postpone the disclosure duties of deployers.

3. When and how to inform people

…in a clear and distinguishable manner at the latest at the time of the first interaction or exposure.Regulation (EU) 2024/1689, Article 50(5)

For evidently artistic, creative, satirical or fictional works the disclosure may be limited to a note that does not spoil the work. The European Commission supports codes of practice on detecting, marking and labelling AI content (Art. 50(7)); following them is the most practical way to show good faith.

4. What happens if you ignore it

Breaching the transparency obligations of Article 50 can be fined with up to EUR 15 000 000 or, for a company, up to 3 % of its total worldwide annual turnover for the preceding financial year, whichever is higher (Art. 99(4)(g)). National market surveillance authorities enforce it.

5. A practical checklist

  1. List every place where your company creates or publishes AI-generated images, video, audio or text.
  2. For each, decide whether you act as a provider, a deployer, or both.
  3. Providers: embed a machine-readable label in every output. The widely read standard is the IPTC “Digital Source Type” field (for example trainedAlgorithmicMedia) in the file's metadata.
  4. Make the label survive the real world: metadata is often stripped when a file is uploaded to social networks, so keep a second, independent way to recognise the file.
  5. Deployers: add a visible notice to deep fakes and to AI-written public-interest texts, no later than first exposure.
  6. Keep evidence: what was labelled, when, and by whom — you may have to show it to an authority.

6. How Ankorith helps

Ankorith is a tool, not legal advice. Whether a particular use counts as a deep fake or as public-interest text depends on your situation; if in doubt, ask your lawyer.

Try Ankorith: verification is free · Pricing · API for developers

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