GuidanceGuidancev1.0.0

The deployer cannot rely on the provider's machine-readable marking

Whoever publishes a deepfake must apply a label perceivable by humans. The watermark or metadata supplied by the provider does not discharge that duty.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

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Identifier: praxikon:eu:ai-act:guidance:guidance-article-50-deployer-perceivable-labelling
Payload hash (sha256): 85008088c20a5e3f90ddaa51118c0e8e86353a579c51168dd58a2f274d497f9e

Citation line

Praxikon, "The deployer cannot rely on the provider's machine-readable marking", praxikon:eu:ai-act:guidance:guidance-article-50-deployer-perceivable-labelling@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z, sha256 85008088c20a5e3f90ddaa51118c0e8e86353a579c51168dd58a2f274d497f9e

Version: 1.0.0
Legal time (effective_at): 8 August 2026
Knowledge time (known_at): 8 August 2026
Closed on: Not closed
Topics: guidance

Review status: Placed against the official source (8 August 2026). Next check due by 4 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

The obligation this hangs off

1 of 1 shown

The object belongs to this obligation. The source line it hangs off sits there.

Source
Official fact on this object, with its locator.
- Guidelines on Article 50
  Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 6.1.2 point (117) and Section 2.3 points (12) and (14)
  praxikon:eu:ai-act:source:commission-article-50-guidelines
  Open official source
Via
- Condition | allApplies to deployers of AI systems that generate or manipulate deep fakes in the form of image, audio or video content.
- ExceptionAn attenuated form of disclosure applies to deep fakes forming part of evidently artistic, creative, satirical, fictional or analogous works, and an exception applies to use authorised by law to detect, prevent, investigate or prosecute criminal offences.
As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.
Consequence
- ObligationArticle 50: transparency
  praxikon:eu:ai-act:obligation:article-50-transparency

What this object is about

1 of 1 shown

The object is about this role. Undifferentiated: it does not follow that the duty rests on this role.

Source
Official fact on this object, with its locator.
- Guidelines on Article 50
  Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 6.1.2 point (117) and Section 2.3 points (12) and (14)
  praxikon:eu:ai-act:source:commission-article-50-guidelines
  Open official source
Via
- Condition | allApplies to deployers of AI systems that generate or manipulate deep fakes in the form of image, audio or video content.
- ExceptionAn attenuated form of disclosure applies to deep fakes forming part of evidently artistic, creative, satirical, fictional or analogous works, and an exception applies to use authorised by law to detect, prevent, investigate or prosecute criminal offences.
As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.
Consequence
- ActorDeployer
  praxikon:eu:ai-act:actor:deployer

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

Point (117) of the guidelines of 20 July 2026 states that deployers of AI systems generating or manipulating deep fake content must clearly and distinguishably disclose that the content has been artificially created or manipulated, by labelling the output accordingly and disclosing its artificial origin. According to that same point, the labelling or disclosure methods used must be understandable and perceivable by natural persons, for example with visible or audible labels, without those persons needing to rely on any specific technical tools or performing dedicated actions. The point closes expressly by stating that deployers cannot rely on the machine-readable marking embedded in the content by the provider under Article 50(2), since those markings are not immediately clear and distinguishable for the natural persons exposed to the deep fake content. Point (12) adds that deployers involved in complex content production and distribution value chains must take proportionate measures to ensure that the labelling they have implemented under Article 50(4) is actually displayed in a clear and distinguishable manner to the targeted and foreseeable audience at the point of first exposure, for example via contractual conditions with distributing partners and via user experience settings and interfaces. Point (14) states that a legal person remains the deployer even where it involves third parties such as contractors or freelancers in the operation of the system on its behalf and under its authority, and that individual employees acting under its instructions and control are not considered separate deployers.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 6.1.2 point (117) and Section 2.3 points (12) and (14)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

This is the sharpest role confusion in the whole transparency chain. Provider and deployer carry two different duties aimed at two different audiences: the provider marks machine-readably for systems and supervisors, the deployer labels perceptibly for humans. The common error is that a marketing department or agency assumes the generated image is 'already marked' by the tool and that nothing further is needed at publication. That is wrong. Equally important is how the duty travels down the chain: it does not end with applying the label, but with whether the audience actually sees the label at first exposure. If your label disappears because a platform re-encodes, crops or auto-plays the video without the opening title, the label formally exists but functionally does not. That is why the guidelines expressly name contractual arrangements with distribution partners as a means. And note the last sentence of point (14): you do not pass the deployer role on to the agency or freelancer producing the content for you.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 6.1.2 point (117) and Section 2.3 points (12) and (14)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

Add a separate step to your publication process in which a label visible or audible to humans is applied to deep fake content, independent of whatever the generation tool writes into the files. Verify per distribution channel that the label is still visible at first contact after uploading, re-encoding and auto-play. Write the labelling requirement into your terms with agencies, production partners and distribution platforms, and do not assume that engaging an external agency moves the deployer role.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 6.1.2 point (117) and Section 2.3 points (12) and (14)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

When this applies

1Applies to deployers of AI systems that generate or manipulate deep fakes in the form of image, audio or video content.

When this does not apply

An attenuated form of disclosure applies to deep fakes forming part of evidently artistic, creative, satirical, fictional or analogous works, and an exception applies to use authorised by law to detect, prevent, investigate or prosecute criminal offences.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "The deployer cannot rely on the provider's machine-readable marking",
praxikon:eu:ai-act:guidance:guidance-article-50-deployer-perceivable-labelling@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0),
effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 85008088c20a5e3f90ddaa51118c0e8e86353a579c51168dd58a2f274d497f9e,
https://www.praxikon.com/en/verkenner/guidance/guidance-article-50-deployer-perceivable-labelling
(https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aguidance%3Aguidance-article-50-deployer-perceivable-labelling&effective_at=2026-08-08&known_at=2026-08-08&lang=en, accessed 2026-08-25)

Short form

praxikon:eu:ai-act:guidance:guidance-article-50-deployer-perceivable-labelling@1.0.0 (sha256 85008088)

BibTeX

@misc{praxikon-eu-ai-act-guidance-guidance-article-50-deployer-perceivable-labelling-1-0-0,
  author       = {{Praxikon}},
  title        = {The deployer cannot rely on the provider's machine-readable marking},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:guidance:guidance-article-50-deployer-perceivable-labelling},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.1.0, schema 1.4.0},
  note         = {effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 85008088c20a5e3f90ddaa51118c0e8e86353a579c51168dd58a2f274d497f9e},
  url          = {https://www.praxikon.com/en/verkenner/guidance/guidance-article-50-deployer-perceivable-labelling},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

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