EU AI Act Article 50 Compliance Checklist
This is a practical checklist of technical measures relevant to Article 50 readiness for teams generating or deploying AI content — synthetic images, audio, video, or text — ahead of the 2 August 2026 enforcement date. It focuses on the technical marking and disclosure side of compliance, not the full legal picture.
This is general information, not legal advice; consult qualified counsel to confirm your specific obligations.
1. Know which Article 50 obligations apply to your role
Article 50 splits obligations by role and content type: providers of generative systems must mark synthetic outputs in a machine-readable, detectable format (Article 50(2)); deployers of deepfake-generating systems must disclose that specific content is artificially generated (Article 50(4)); and deployers publishing AI-generated text on matters of public interest have a related disclosure duty. Confirm whether you're acting as a provider, a deployer, or both, since the measures that apply differ by role.
2. Technical measures worth having in place
For providers: attach a machine-readable marker to every synthetic output at generation time, ideally one backed by a cryptographic signature rather than easily-stripped metadata alone, and add a resilient fallback such as a watermark so the marking survives ordinary recompression, resizing, and re-uploading. For deployers: make sure any AI-generated or AI-manipulated deepfake content carries a clear, audience-facing disclosure, and keep an audit trail of what was disclosed and when, since demonstrating compliance after the fact matters as much as the disclosure itself.
3. Verification and record-keeping
Make sure marked content can actually be checked — by regulators, platforms, or the public — not just produced. A free, publicly accessible verification path, rather than one requiring an account or payment, supports the transparency intent behind Article 50 more directly than marking that only your own systems can read. Keep signing records and audit logs available through the enforcement window, since the transitional period runs through 2 December 2026 for systems already on the market.
4. Where Certivu fits
Certivu signs AI-generated content with post-quantum ML-DSA signatures at creation time, layers resilient watermarking and fingerprinting fallbacks so the marking survives ordinary transformation, and offers free, unlimited public verification with no account required — the kind of machine-readable, checkable marking Article 50 is oriented toward. You can try the public verifier or run a short demo to see how a signed asset holds up through resizing, recompression, and re-upload.
FAQ
Is this checklist a substitute for legal advice?
No. This is general information about the technical side of Article 50 readiness, not legal advice. Your specific obligations depend on your role (provider vs. deployer), the AI systems involved, and other applicable law — consult qualified counsel to confirm compliance for your situation.
What's the deadline to have these measures in place?
Article 50 becomes legally binding and enforceable on 2 August 2026. AI systems already placed on the market before that date have a transitional period until 2 December 2026 to come into compliance.
Does signing content with Certivu satisfy Article 50 on its own?
Not by itself. Certivu provides the technical marking and verification infrastructure that can support Article 50's machine-readability and detectability goals, but full compliance also depends on your disclosure practices, role under the Act, and other obligations that a technical tool can't fulfill alone.
Source: European Commission — Code of Practice on Transparency of AI-Generated Content