Article 50 is live today: disclose, mark, and label the deepfakes.
Article 50 has applied since 2 August 2026. Synthetic imagery needs machine-readable marking, deepfakes need a visible label, and a chatbot that sounds human is a breach — with penalties in the same tier as the rest of the Act.
- Annex
- Article 50 — transparency obligations for certain AI systems
- Provisions
- Art. 50(1) · Art. 50(2) · Art. 50(4)
- Pack
- €99/month add-on · 4 duties · 2 notice templates
Why this sector is different
Marketing is the sector where the transparency duty is already enforceable and most visible. It is also the easiest to fix: the controls are a disclosure, a marking step and a review gate before publication.
Put a machine-readable marking step in the publishing pipeline
Marking has to happen at production, not be reconstructed afterwards.
Art. 50(2) · due within 14 days of activation
Add a visible deepfake label to any synthetic depiction of real people
Machine-readable marking is not a substitute for a visible label on a deepfake.
Art. 50(4) · due within 21 days of activation
Disclose AI interaction in every chatbot and voice assistant
A human-sounding persona that does not disclose is the most common Article 50 failure.
Art. 50(1) · due within 14 days of activation
Put the marking and disclosure duty in agency and freelancer contracts
Your agency's deliverables are your exposure. The duty does not stop with the supplier.
Art. 50 · due within 45 days of activation
The notices you owe
Unlocked with the pack, rendered with your own facts, blanks kept where you must decide.
Anyone interacting with the system
Chatbot disclosure line
You are interacting with an AI assistant, not a person. A human can review the conversation on request, and you can ask to be transferred to {contact} at any time.
Audience of the published content
Synthetic media label
This image/video was generated or altered using artificial intelligence. It depicts {subject} and does not show a real event.
What your buyers will ask
The questions that stall a deal or trigger an audit. Each one is a control in the matrix.
- ?How do you mark AI-generated media?
- ?Where is the chatbot disclosure?
- ?Do your agency contracts put the Article 50 duty on the supplier?
Straight answers
Is Article 50 really live now?
Yes. It has applied since 2 August 2026. The Digital Omnibus did not defer it, and the Commission adopted final Article 50 guidelines in July 2026. A transition window for marking systems already on the market closes on 2 December 2026.
Does a human-sounding chatbot need a label?
It must be disclosed that the person is interacting with an AI, unless it is obvious to a reasonably well-informed person. Giving the bot a human name and persona works against you, not for you.
Know where you stand before the questions arrive.
Four minutes, no card. You get your exposure score and the exact articles that apply to a marketing & media organisation.