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

(64) Content generated by an AI system based on simple data processing, which is not specifically AI-generated or manipulated, for example a rendered frame, falls outside the scope of Article 50(2) AI Act.

(65) Furthermore, an AI system’s output that merely reproduces existing content or enables the presentation or arrangement of already existing content is not covered by

Article 50(2) AI Act. This may be the case, e.g., for music playlists or other recommender systems that only select or rank existing content based on user preferences or activity, without creating anything new or manipulating the content itself. The same applies to AI systems used in internal analytical processes that extract and structure data, but do not summarise it.

(66) The same is true for an AI system’s input and output that constitutes mere observations and recordings of data from physical or virtual environments, that is not AI-generated or manipulated (e.g. by robots or other AI-enabled sensors) or data transmissions by AI systems without any alteration. This covers a variety of AI systems’ inputs and outputs, in particular in industrial settings such as manufacturing data for robots observing data; consumption recorded by AI-enabled smart meters, grid frequency and voltage measurements; and recording of GPS location data from vehicles, etc.

(67) Furthermore, since the objective of the transparency obligation in Article 50(2) AI Act is to enable humans to distinguish AI-generated or manipulated content, so as to address the risks of deception, manipulation and ensure integrity and trust in the information ecosystem, any content that is not related to that objective, and that is not perceptible or not intended to be interpreted, verified or acted upon by natural persons, is not targeted by this provision.

(68) In particular, the following content should be considered to fall outside the scope of Article 50(2) AI Act:

- Outputs generated in the form of a short sequence of numbers, symbols or letters (e.g. single words, image captions, alt-text, UI labels and icon-scale graphics, image captions and other data labels);

- Source code understood as content written in a programming, scripting, markup, query or configuration language that is intended to be interpreted, compiled or executed by a computing system, regardless of whether it is composed of text characters. This may also include natural-language comments and contextual information that form an integral part of the source code. Similarly excluded are Software Development Kits (SDKs), Structured Query Language (SQL), infrastructure-as-Code and ‘YAML Ain’t Markup Language’ (YAML), JavaScript Object Notation (JSON) configuration. schemas, scripts, machine-readable specifications, Application Programming Interfaces (APIs & software libraries);

- Outputs of an AI system intended to be exclusively communicated from machine to machine and processed automatically without any exposure to humans, for example agent-to-agent communication, anti-spam signals, as long it is not perceived by natural persons;

- Outputs that are only used in closed loop environments in industrial and product development workflows (for example for film, animation, games or advertising production), unless they are the final output of the AI system in the form of AI- generated or manipulated text, audio, image or video content. In those cases, only the final output from workflow stages has to be marked and detectable.