TRACENOTICE · ARTICLE 50 IMPLEMENTATION GUIDE

Synthetic-content marking: evidence the mechanism, not just the policy.

Article 50(2) requires providers of AI systems that generate synthetic audio, image, video or text to ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, subject to the regulation’s limitations and exceptions. Article 50(4) adds disclosure duties for certain deepfakes and public-interest text published by deployers.

Engineering translation: document which generation paths produce machine-readable provenance/marking, how it survives normal transformations, what the underlying model/provider supplies, and what visible labelling is required at publication surfaces.

Technical evidence checklist

  1. Inventory each synthetic-content modality and generation path.
  2. Identify the marking/provenance mechanism supplied by the model or media pipeline.
  3. Test representative outputs after download, resizing, transcoding or other normal transformations.
  4. Capture test files, metadata/provenance outputs and provider documentation.
  5. Separate provider-side marking duties from deployer-side visible disclosure duties.
  6. Map deepfake/public-interest publication surfaces and exceptions for legal review.
  7. Version the evidence with the model/provider and application release.

Transition detail

Article 50 applies from 2 August 2026. The Commission states a limited transition to 2 December 2026 for Article 50(2) marking/detection obligations for qualifying systems placed on the market before 2 August 2026.

Primary sources

EU AI Act consolidated text — Article 50
Code of Practice on Transparency of AI-generated Content
European Commission Article 50 FAQ

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