Set up human review as a real editorial checkpoint: assign a knowledgeable reviewer who can verify the substance, require changes or reject the draft, and ensure an accountable editor authorizes publication. Proofreading alone is not substantive review. The right level of scrutiny depends on the content’s potential impact and, where relevant, the law that applies to your organization.
What counts as human review?
For the European Union’s Article 50 transparency exception concerning certain AI-generated text, the European Commission defines human review as “the deliberate examination of the substance of the content by one or more natural persons possessing relevant knowledge and professional judgement pertaining to the subject matter under scrutiny.” In practice, that means examining whether the content is accurate, supported, and fit to publish—not just whether it reads smoothly.
The Commission describes editorial control as practical control by a responsible editorial entity, such as an editor-in-chief, with authority to approve, alter, or reject the substance on substantive grounds. That includes fact-checking and checking whether sources are trustworthy. It also says that “Superficial, solely formal, or procedural checks (e.g. spell-checking or grammatical correction) are not considered to be human review or editorial control.” European Commission FAQ on transparency obligations under Article 50
These definitions explain an exception within a particular EU transparency rule; they do not establish that every AI-assisted draft in every country must undergo the same legally mandated review.
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How to build a review workflow
- Define what must be reviewed. Specify which AI-assisted materials need approval before publication and what publication-ready means. Set a more intensive review path for content where errors could affect health, safety, rights, finances, or public understanding. This risk-sensitive approach is consistent with the EU AI Act’s requirement that oversight of high-risk AI systems reflect risk, autonomy, and context.
- Assign a qualified reviewer. Choose a person with knowledge and professional judgment relevant to the claims. A general editor can assess structure and clarity, but specialized medical, legal, scientific, or financial claims may need a subject expert. Familiarity with AI tools is not a substitute for subject expertise.
- Check claims and sources. Verify important factual statements against reliable sources. Inspect citations and quotations, and look for unsupported assertions, missing context, misleading framing, or fabricated details. Treat fluent language as presentation, not evidence.
- Give the reviewer decision authority and time. The reviewer should be able to require edits, reject the draft, or stop publication. A process that defaults to approval or permits only grammar corrections does not provide meaningful editorial control as described by the Commission.
- Escalate uncertainty and consequential claims. Route claims the reviewer cannot validate to a subject expert or responsible editor. Escalate unexpected system behavior and content with potentially serious consequences instead of asking the first reviewer to guess.
- Record the decision. Keep a lightweight record of the content version, reviewer and relevant expertise, substantive checks, significant corrections or unresolved issues, final decision, and responsible editor. This is practical implementation advice; the Commission does not prescribe this exact record template.
- Revisit the process when it stops working. Sample published work and update instructions when errors recur, the AI system changes, or new uses are introduced. The EU AI Act supports monitoring and the ability to intervene for high-risk systems, but the cited sources set no universal sampling schedule for editorial teams.
What to check before publication
- Factual accuracy: Can the central claims be verified, and do the sources support the wording used?
- Source quality: Are cited sources genuine, relevant, and trustworthy? Do quotations accurately reflect their context?
- Completeness and framing: Has the draft omitted a qualification, counterpoint, or uncertainty that would materially change a reader’s understanding?
- Unsupported specifics: Are there names, dates, numbers, examples, or causal claims that appear precise but lack evidence?
- Publication decision: Is the material ready, does it need correction or expert review, or should it be rejected?
Grammar, tone, and readability can be part of editing, but they do not replace these substantive checks.
Additional oversight for high-risk AI systems
Article 14 of Regulation (EU) 2024/1689 requires effective human oversight during the use of high-risk AI systems. Measures must be proportionate to the system’s risks, autonomy, and context. People assigned to oversight need to understand the system’s capabilities and limitations, monitor for anomalies and unexpected performance, account for automation bias, interpret outputs, disregard or reverse them, and intervene or stop the system safely. Regulation (EU) 2024/1689, Article 14
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This is broader than an editor checking a finished article: where Article 14 applies, oversight concerns how the high-risk system is used and whether people can intervene. The Act’s requirement for separate confirmation by at least two competent, trained, and authorized people applies only to a specified biometric identification context in Annex III. It is not a general two-person approval rule for AI-written content.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Does human review affect EU labeling duties?
The European Commission says Article 50’s transparency obligations apply from 2 August 2026. The rules distinguish provider duties to mark synthetic outputs in machine-readable form from deployer duties to label certain exposed content. For text, the relevant labeling rule concerns AI-generated or manipulated text published to inform the public on matters of public interest. The Commission identifies areas such as political and public administration matters, justice, rights, security, public health, environmental and consumer safety, economic and financial developments, science, and culture when relevant to public debate.
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The public-interest text labeling rule has an exception where the AI-generated or manipulated text has undergone human review or editorial control and a natural or legal person holds editorial responsibility for publication. The Commission explains that editorial responsibility means a person holds ultimate legal responsibility for publication, including the review or editorial control. Whether a particular publication or item falls within the rule depends on its facts and jurisdiction; do not assume a review process automatically resolves every disclosure obligation. European Commission FAQ on Article 50 transparency obligations · European Commission guidance on human review and editorial control
The Commission’s Code of Practice is a voluntary compliance tool for the covered marking and labeling duties. Organizations that do not follow it must demonstrate compliance by other adequate means. European Commission Code of Practice
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Common process failures
- Only correcting grammar: Fluency can hide incorrect claims. Include source and substance checks.
- Assigning an approver without authority: A reviewer who cannot request changes or block publication is not exercising meaningful editorial control.
- Using the wrong expertise: A reviewer should be capable of judging the subject matter, not merely the AI’s writing style.
- Approving by default: Make approval a decision after review, not the automatic result of receiving a draft.
- Confusing editorial review with system oversight: A final read-through does not by itself provide the monitoring and intervention capability Article 14 requires when it applies to a high-risk system.
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