EU law does not require an AI label on every AI-assisted sentence. From 2 August 2026, the AI Act requires a publisher or other deployer to clearly disclose certain AI-generated or manipulated text published to inform the public about a matter of public interest. A substantive human review or editorial control can take that text outside this disclosure rule when a person or organization also holds editorial responsibility. Being regulated, by itself, does not decide whether the rule applies.
When does the EU AI Act require disclosure of AI-generated text?
Article 50 of the EU AI Act distinguishes the organization that provides an AI system from the organization that uses it. For a publisher, the key question is usually whether it is a deployer: the person or organization using an AI system under its authority for a professional activity that is not personal. An organization can remain the deployer when its employees, contractors or freelancers use the system on its behalf and under its responsibility and control.
The deployer’s text-disclosure duty is narrower than “label anything touched by AI.” It applies when AI-generated or manipulated text is published with the purpose of informing the public on a matter of public interest, unless the editorial exception applies. The subject and purpose of the particular publication matter; a sector’s regulated status alone is not the test.
What can count as a matter of public interest?
European Commission guidance gives examples including politics and democratic processes, public administration, justice and law enforcement, fundamental rights, public security, public health, environmental protection, consumer safety, and economic, financial, political, scientific or cultural developments relevant to public debate. A health publisher should assess whether a specific article informs the public about public health; a finance publisher should assess whether its subject concerns a financial development relevant to public debate. Do not assume every service page, internal document or regulated claim has the same purpose or scope.
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Who must do what: provider marking versus publisher disclosure
Article 50 contains separate obligations. A provider’s technical marking is not a substitute for a deployer’s reader-facing notice where one is required.
| Question | Provider obligation | Deployer or publisher obligation |
|---|---|---|
| What is covered? | Synthetic audio, image, video and text outputs. | Text published to inform the public about a matter of public interest; other distinct duties cover specified deepfakes and AI interactions. |
| What is required? | Ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, to the extent technically feasible and subject to exceptions. | Provide a clear, distinguishable human-facing disclosure when the applicable rule requires one, unless an exception applies. |
| Who is responsible? | The system provider. | The person or organization using the system under its authority for professional activity, including an organization whose staff or contractors use it under its responsibility and control. |
The European Commission’s Article 50 FAQ explains that deployers cannot simply rely on a provider’s embedded machine-readable marking to meet the disclosure obligation. A provenance signal may help identify content, but it does not by itself tell a reader what they need to know.
When can substantive human editorial work remove the text-label duty?
The Article 50 text rule does not apply if the AI-generated content underwent human review or editorial control and a natural or legal person holds editorial responsibility for publication. These conditions are substantive: a quick sign-off, spell-check or grammar-only correction is not enough.
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Human review
The Commission describes human review as deliberate examination of the content’s substance by someone with relevant subject knowledge and professional judgment. In practice, the reviewer should assess what the text says, not merely how it reads. Depending on the article, that can include checking factual claims, reviewing sources and deciding whether the content is suitable to publish.
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Editorial control
Control must operate in practice. The editor or organization needs authority to approve, change or reject the substance on substantive grounds, including fact-checking and assessing the trustworthiness of sources. The Commission’s FAQ states: “Superficial, solely formal, or procedural checks (e.g. spell-checking or grammatical correction) are not considered to be human review or editorial control.”
Editorial responsibility
A natural or legal person must hold ultimate legal responsibility for the publication, including the review or control. A human contribution somewhere in the production chain is not, on its own, the full exception. For a defensible account of the workflow, record who reviewed the text, what substantive checks took place, who could change or reject it, and who accepted responsibility. The cited Commission guidance does not prescribe a particular recordkeeping form.
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How should a required AI disclosure appear?
Article 50 requires relevant information to be given clearly and distinguishably no later than the first interaction or exposure, and requires compliance with applicable accessibility requirements. For a text publication, a practical approach is to put a concise notice where readers encounter it before or when they read the relevant content. The sources do not prescribe one universal phrase, icon, position or format for every text disclosure, so treat house wording as an editorial choice rather than statutory language.
A hidden machine-readable mark alone is not a reader-facing disclosure. The Commission’s deepfake guidance says the notice should be perceivable without a special technical tool or an extra action, such as through a visible or audible label. The same practical distinction matters when choosing a publication workflow: machine-readable provenance and an accessible human-readable notice serve different purposes.
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Text is only one part of Article 50. Publishers and service operators should check the type of material or interaction as well as the public-interest test.
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AI-generated or manipulated images, audio and video
A deployer must disclose content that qualifies as a deepfake: AI-generated or manipulated content that resembles existing persons, objects, places, entities or events and would falsely appear authentic or truthful. Context matters to whether it creates that false impression. For an evidently artistic, creative, satirical, fictional or analogous work or programme, the disclosure is limited to an appropriate notice that generated or manipulated content exists, without hampering display or enjoyment.
Direct AI interaction and biometric systems
Providers of systems intended to interact directly with people must inform them that they are interacting with AI unless that is obvious in context. Deployers of emotion-recognition or biometric-categorisation systems must inform people exposed to those systems about their operation. These are separate transparency duties, not rules for labelling AI-written text.
Sector-specific and national obligations
Article 50 leaves other Union and national transparency requirements in place. An AI-origin notice does not, by itself, disclose advertising or sponsorship, substantiate a health or financial claim, provide a required product warning, or satisfy professional or consumer-information rules. The applicable obligations depend on the subject, service, audience, Member State and publication context. Assess those rules separately and obtain sector-specific legal review when the consequences warrant it; Article 50 guidance is not a survey of every national law or regulated sector.
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A practical decision path for an editorial team
- Assign the role. Decide whether your organization provides the AI system, deploys it, or does both. Account for staff, contractors and freelancers using the system under your organization’s responsibility and control.
- Classify the material. Identify whether the output is text, an image, audio, video, a direct AI interaction, or exposure to an emotion-recognition or biometric-categorisation system.
- For text, assess scope. Ask whether AI generated or manipulated the text, whether it is being published to inform the public, and whether its subject is a matter of public interest. Do not use regulated status as a shortcut for this assessment.
- Assess the editorial exception. Determine whether a qualified person substantively reviewed the content or an editor exercised substantive control, and whether a person or organization holds editorial responsibility. Routine proofreading alone does not qualify.
- Make any required notice usable. Ensure it is clear, distinguishable, accessible and encountered no later than first exposure. For a deepfake, ensure people can perceive the notice without technical tools or an additional action.
- Check other applicable rules. Separately assess Union, national and sector-specific transparency or consumer-information requirements for the material and publication context.
- Keep a record of the decision. Note the facts supporting the scope assessment, exception and notice choice. This is practical editorial advice; the cited materials do not establish a prescribed record format.
Which date and transition rules apply?
Article 50 applies from 2 August 2026. The Commission’s FAQ describes a limited transition until 2 December 2026 for providers’ Article 50(2) marking and detection duties on AI systems placed on the market before 2 August 2026. That transition is not a general delay for deployers’ public-interest text disclosures. The FAQ also says content generated before 2 August 2026 does not require retroactive labelling under the AI Act, although the Commission encourages labelling it where possible.
The European Commission published its final Article 50 guidelines on 20 July 2026. It describes the Code of Practice on Transparency of AI-Generated Content as a voluntary implementation tool: adherence to the code is not itself mandatory, though the underlying Article 50 duties are legal obligations. The Commission says it and the AI Board assessed the code as adequate for signatories to demonstrate compliance with relevant marking and labelling duties; organizations using alternative means should be ready to show those means are adequate. Because these dates and implementation details are time-sensitive, verify the consolidated law and current Commission guidance for the publication date and relevant jurisdiction.
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