Applicable to: AI deployers.
Date of application: 2 august 2026.
Objective: to disclose that a text intended to provide information on matters of public interest has been artificially generated or manipulated.
Regulation (EU) No 1689/2024 on Artificial Intelligence (AI Act) of 13 June 2024 introduced a series of transparency obligations within the European Union for suppliers and deployers of AI systems, even where such systems pose a limited risk (the lowest risk level assigned to certain AI systems under the risk-based approach adopted by the AI Act).
In this article, we will analyse the obligation covered by Article 50.4 of the AI Act, under which it is provided for:
Deployers of an AI system that generates or manipulates text which is published with the purpose of informing the public on matters of public interest shall disclose that the text has been artificially generated or manipulated. This obligation shall not apply where the use is authorised by law to detect, prevent, investigate or prosecute criminal offences or where the AI-generated content has undergone a process of human review or editorial control and where a natural or legal person holds editorial responsibility for the publication of the content.
The key feature of this obligation is that the text generated or manipulated by an AI system has been published with the purpose of informing the public on matters of public interest.
The informations must be provided to the persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure.
Regarding the measures to be taken to disclose the artificial nature of the text, the European Commission is drafting a Code of practice on transparency of AI generated contents (the final version of which should be approved within the month of June 2026).
The draft Code published in march 2026 states the use of an icon consisting of the acronym “AI”, that must be clear, accessible, and recognizable, placed in a suitable and clearly visible location, in accordance with the content format and dissemination context.
The AI Act provides for two circumstances in which the obligation does not apply.
- Firstly, there is no obligation to disclose that the text has been manipulated or generated synthetically if the content has undergone a process of human review or editorial control and a natural or legal person holds editorial responsibility for the publication of the content. In this case, therefore, the exemption requires that a person (natural or legal) assume full responsibility for the information provided.
- Finally, this obligation does not apply where the use of the manipulated or artificially generated text has been authorised by law for the purpose of detecting, preventing, investigating or prosecuting criminal offences.
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