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// AI Act · Art. 50 overview

AI Labelling.
Art. 50 since 2 August 2026.

Since 2 August 2026, Art. 50 of the EU AI Act requires AI content to be made transparent: deepfakes and certain AI texts must be clearly disclosed as AI-generated. We make your AI content compliant, without slowing your production down.

Mandatory since 02 Aug 2026 Art. 50 AI Act Deepfakes Up to €15M fine DACH-wide
Art. 50

of the EU AI Act governs the transparency obligations

02 Aug 26

binding and applicable from this date

€15M

or 3 % of worldwide turnover: fine per breach

Deepfake

defined very broadly: almost any photorealistic AI image

// The Obligation

What Art. 50
requires of you.

Art. 50 of the EU AI Act (Regulation (EU) 2024/1689) governs the transparency obligations for AI content. It distinguishes between providers (who build the AI system) and deployers (who use AI professionally). For companies and agencies, the deployer role is usually the relevant one.

Important: the label says nothing about truth or quality, only about the artificial origin. It protects public opinion-forming and trust in the information ecosystem.

A deepfake is defined in Art. 3(60) AI Act as AI-generated or manipulated image, audio or video content that resembles real persons, places or events and would falsely appear authentic. The wording is extremely broad: as of today almost any photorealistic AI image can fall under it.

Note: AI Pirates is an AI agency, not a law firm. This page describes the situation in plain language. For a binding legal assessment of your individual case, please coordinate with your legal department.

The obligations under Art. 50

→ Para. 1: disclose AI interaction (chat/voicebots): provider
→ Para. 2: machine-readable output marking: provider
→ Para. 4 s. 1: disclose deepfakes visibly: deployer
→ Para. 4 s. 4: AI text of public interest: deployer
→ Para. 5: clear, unambiguous, accessible, immediate

// Implementation

Labelling
by format.

Images

→ Label "AI" / "AI GENERATED", capitalised
→ Consistent position, e.g. top right
→ Highest possible contrast, at least 4.5:1 (accessibility)
→ Large enough to read as a central visual element
→ Don't hide it in the background

VISIBLE ON FIRST VIEW: INCLUDING FOR LOW VISION

Videos

→ Short video (Reels/TikTok/Shorts): label throughout
→ Long video: at start + regular intervals
→ Live: continuously if possible
→ Credits-only notice is not enough

NOT BEHIND UI ELEMENTS

Audio

→ Under 30 sec: spoken notice at the start
→ Over 30 sec: notice at start, middle, end
→ Clearly spoken, in the local language
→ With a display: add a visual icon
→ Any human-sounding AI voice must be labelled, not just cloned ones

PODCASTS, VOICEBOTS, SPOTS

Text

→ Mainly for matters of public interest
→ Notice near the headline / above the text
→ Purely promotional text mostly exempt
→ Final human review usually exempts

BLOG, NEWS, PR

Visibility beats metadata: C2PA metadata is a good technical foundation but is lost on re-upload and screenshots, and does not exempt you from visible labelling.

// Exceptions

When you don't have
to (fully) label.

Art & satire

For evidently artistic, creative or satirical works the obligation is softened: a discreet notice that doesn't impair enjoyment of the work suffices. The exception is loosely worded, though. Relying on "art" for advertising content carries a high liability risk.

Human-in-the-loop

AI texts are exempt if subjected to human review / editorial control and a person bears editorial responsibility. A demonstrable final human edit usually exempts you.

Law enforcement

The disclosure obligation does not apply where use is legally permitted to detect, prevent, investigate or prosecute criminal offences. Rarely relevant for companies and agencies in practice.

// Risk & deadlines

What's at
stake.

Sanctions

→ Fine up to €15M or 3 % of worldwide turnover (Art. 99 AI Act)
→ Competition-law warnings by competitors & consumer bodies: already today
→ Risk of a deception/misleading claim for missing labels
→ The AI deployer is liable: whoever operates the AI, not the model provider
→ Secure client & freelancer contracts with a labelling clause
→ Enforcement bodies are already gearing up

8 May 2026 · Draft guidelines

The EU Commission publishes draft guidelines on Art. 50.

10 June 2026 · Code of Practice

Voluntary code published: eases the compliance proof. First signatory deadline: 22 July 2026.

2 Aug 2026 · Obligation applies

Art. 50 becomes binding. From now on fines and warnings are possible.

2 Feb 2027 · Interoperability

Deadline for interoperable watermark detectors (Code of Practice).

// How to do it right

Putting the obligation
into practice.

When in doubt, label

Whether and how to label is case-by-case. Given the broad deepfake definition, defensive, generous labelling is the safest route.

Tool whitelisting & policy

Only vetted AI tools with compliant watermarks / C2PA, a clear internal AI policy, clauses for external creators. We build that for you.

Secure your evidence

Document original prompts, apply a four-eyes principle before publishing. That proves the human share and keeps you covered if questioned.

// Self-check

Do I have to
label this?

A first assessment in 2-3 clicks. Not legal advice: an orientation based on Art. 50 AI Act.

The result is a non-binding orientation. For a legally sound assessment of your case, please consult your legal department or a specialist lawyer. We are also happy to review your content in a labelling audit.

// Free download

AI Labelling
Checklist 2026

A 4-page PDF (in German) covering who is affected, labelling by format (image, video, audio, text), exceptions and 8 actions for implementation.

// FAQ

Frequently asked
about labelling.

When does the AI labelling obligation under Art. 50 apply?

Since 2 August 2026. AI providers must mark outputs in a machine-readable way; AI deployers must disclose deepfakes and certain AI-generated texts clearly and perceptibly as AI-generated.

Do AI-generated images have to be labelled?

Usually yes. The deepfake definition (Art. 3(60) AI Act) is very broad: as of today, any photorealistic AI image resembling real persons, objects or events can be a deepfake that requires labelling. When in doubt, label.

What does an AI label have to look like?

Clear, unambiguous and accessible, at the latest on first view. Recommended: a label "AI" in capitals, highest possible contrast (at least 4.5:1) and large enough to be readable as a central visual element even for people with low vision: platform-appropriate display, continuous for short videos, spoken notices for audio.

Do AI voices have to be labelled?

Yes, as soon as the voice sounds human. The assumption that only cloned voices of real people require labelling is wrong: synthetic AI stock voices also trigger the obligation if they sound human. Implement it via a spoken notice, plus a visual icon where a display is present.

Do AI-generated marketing texts have to be labelled?

Mostly not. The text obligation applies primarily to text of public interest. Purely promotional text often falls outside it, and a final human review with editorial responsibility additionally exempts it.

Are C2PA metadata enough for labelling?

No. Metadata is a useful technical foundation but is easily lost (re-upload, screenshots). The AI Office acknowledges this: presence of metadata does not exempt you. Deepfakes and relevant AI texts must be labelled perceptibly for humans: visibility beats metadata.

What are the penalties for non-compliance?

Under Art. 99 AI Act up to €15M or 3 % of worldwide annual turnover (whichever is higher). Plus competition-law warnings by competitors and consumer bodies. For an individual legal assessment we recommend your legal department.

// Related AI Services

AI Act Training AI Training AI Consulting AI Creative AI Glossary

// Act now

Make your AI content
compliant.

In a free 30-minute intro call we review your AI content and your labelling risk. If needed, we then set up your policy, tool whitelist and training with you. The obligation has applied since 2 August 2026.

Request a labelling audit