Guidelines on the implementation of the transparency obligations for certain AI systems under Article 50 of the AI Act — C(2026) 5054 final, Annex

(57) Article 50(2) AI Act applies to AI systems (26), including GPAI systems, generating synthetic audio, image, video or text content. Article 50(2) AI Act covers a subset of systems that fulfil the AI system definition in Article 3(1) AI Act and that generate such outputs. Article 50(2) AI Act also covers AI systems used to manipulate content.

(58) Content generation refers to the generation of synthetic material by the AI system (e.g. based on a human prompt), such as generating a synthetic image or a song. In practice, this means that Article 50(2) AI Act may apply to generative AI systems designed with a narrow intended purpose to produce specific outputs. At the same time, Article 50(2) AI Act also applies to AI systems that may serve multiple purposes, including GPAI systems, and can produce a variety of types of content, as well as agentic AI systems, so long as they generate synthetic audio, image, video or text content.

(59) By contrast, content manipulation refers to already existing content (whether synthetic or not) that is altered by an AI system (e.g. an existing image or a voice recording that is manipulated by an AI system in accordance with human instructions). For content to fall under Article 50(2) AI Act, it is sufficient that it is AI-generated or manipulated beyond standard editing under the exceptions set out in Article 50(2) AI Act (see Section 4.3). Additionally, Article 50(2) AI Act does not require that the content is solely AI- generated or manipulated. Content that is mixed with human-created material also qualifies as synthetic content, if manipulated or generated in one of the modalities referred to in Article 50(2) AI Act.