Article 50 splits the work. Providers of generative systems owe machine-readable marking so synthetic audio, image, video and text can be detected. Deployers who publish deepfakes — content resembling real people, places or events that would appear authentic — owe a visible or audible label at first exposure. The Commission's transparency FAQ is the primary source (digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act). The two duties produce two artefacts. A watermark is not a caption. A caption is not a detector mark.
If you sign in to a hosted generator, prompt it, download the file and post it, you are a deployer of that system. You did not place it on the market. You cannot retrofit machine-readable marking if the export does not carry it. What you can do, and what 50(4) asks you to do, is put a label a person can perceive on the published work. Agencies, brands, in-house teams and solo creators sit here for almost every clip they commission.
Artistic, creative, satirical or fictional works may label in a way that does not spoil the work. Standard assistive editing is exempt. Public-interest AI text needs a label unless a human actually edited the claims. Content generated and published before 2 August 2026 is not retroactive; generated before and published after is covered. A platform AI toggle may help. It does not replace the legal test, which follows the audience and the content, not the app.
In practice
- If you published the clip, assume you are the deployer until a lawyer tells you otherwise.
- Put the label on the file at first exposure — first frame, not the description field.
- Do not wait for the generator's watermark to 'cover' you. That mark is the provider's job, aimed at a detector.
The mistake to avoid
Thinking the tool's embedded watermark discharges the duty to tell a person the clip is synthetic. Different duty, different reader.
Go deeper
Provider or deployer: who labels under Article 50
Providers mark output in machine-readable form; deployers label deepfakes visibly on first exposure. Here is which role you occupy on a hosted generator.
Related terms
Provider (AI Act)
A provider under the EU AI Act places a generative system on the market and owes machine-readable marking of synthetic output, not the on-screen label.
Article 50
Article 50 of the EU AI Act is the 2 August 2026 transparency rule: labels on certain AI interactions, synthetic media, and public-interest AI text.
Deepfake
A deepfake, in Article 50, is AI audio, image or video that resembles real people, places or events and would appear authentic to a person.
Synthetic media disclosure
Synthetic media disclosure is the broader legal obligation to identify AI-generated or altered content as such — increasingly a binding requirement rather than a platform preference, with the EU AI Act's Article 50 as the clearest current example.
Spark Ads
Spark Ads meaning: TikTok budget behind an existing post (yours or a creator's) so paid reach keeps the real likes, comments, and shares.
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