Which AI text needs a label: published, informing the public, on a matter of public interest

Point (131) of the guidelines of 20 July 2026 splits the scope of Article 50(4), second subparagraph, into three elements. Published text means the text is accessible by an indeterminate, fairly large number of unrelated potential readers simultaneously or successively, whether or not against payment such as a subscription. Text is not considered published where access is restricted to specific individuals within a closed, private group, for example a small closed group on an instant messaging app or a group that is too small or insignificant; the document cites as examples of unpublished text private interpersonal correspondence for professional purposes and organisation-internal texts or communications such as publications on internal corporate networks. Informing the public means the text intends to communicate knowledge, opinions or facts; short texts that do not materially communicate knowledge, opinions or facts cannot be deemed to inform the public. Matters of public interest are, according to that same point, generally those relevant to society at large, at local, national, Union or international level, and meriting public debate or scrutiny; the document includes texts on politics and democratic processes, public administration and services, the administration of justice and law enforcement, the protection of fundamental rights, public security, public health, environmental protection, consumer safety, and any economic, financial, political, scientific or cultural development that may be a relevant subject of public debate, noting that what counts as public interest can evolve over time and across contexts. As examples within scope the document cites an AI-generated summary of a human-authored article on a newspaper's website discussing a recent town council decision, AI-manipulated parts of a lifestyle-website article comparing the effects of various diets on a particular disease, AI-manipulated corporate reports containing investor information published on a listed company's website, and an AI-generated message on a meteorological institute's social media profile warning citizens about stormy weather and precautionary measures. Outside scope the document places among others AI-generated fantasy novels, AI-manipulated text that is part of a company's advertisement or product descriptions without claims relating to for example health, consumer safety or sustainability, a news summary generated by a chatbot that is only available to the user who prompted it, and AI-manipulated text by a consultant advising a client on measures for regulatory compliance.

• Locator: Commission Guidelines C(2026) 5054 final, Section 6.2.1 point (131) and the accompanying example listspraxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

The reflex is to read this as a media rule that only concerns newsrooms. The examples show otherwise. A listed company with AI-edited investor information on its own website is inside. A meteorological institute posting a storm warning on social media is inside. A lifestyle site with health claims is inside. What binds those cases is not that they are journalism, but that a broad audience draws information from them about something that affects society. The second nuance sits on the other side: an advertisement or product description falls outside, but only as long as it carries no claims about health, consumer safety or sustainability. Sustainability claims in commercial copy therefore move into scope. The third nuance is the split between internal and published: your intranet and your one-to-one correspondence fall outside, even where the content is socially relevant. And note: the presence of the AI-generated summary of a human-authored article in the example list means the automatic summary feature under a news article can by itself trigger the labelling duty.

• Locator: Commission Guidelines C(2026) 5054 final, Section 6.2.1 point (131) and the accompanying example listspraxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

Walk through your publication channels and flag where AI generates or substantially edits text: news items, knowledge articles, annual reports and investor information, public information and citizen warnings, and sustainability or health claims. Assess per channel whether the text is published in the sense of the guidelines, meaning accessible to an indeterminate and fairly large audience. Treat automatic summary features on articles as a separate, standalone assessment rather than as part of the underlying article.

• Locator: Commission Guidelines C(2026) 5054 final, Section 6.2.1 point (131) and the accompanying example listspraxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source