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

(69) Article 50(2) AI Act sets out a transparency obligation for providers of generative AI systems falling within the scope of that provision comprising two distinct, but inherently interlinked elements. First, providers must ensure that the outputs of the AI system are marked in a machine-readable format. Second, providers must ensure that the outputs are detectable as artificially generated or manipulated content. For every marking solution deployed, providers should ensure that corresponding means for detection are available (as outlined below) to enable natural persons exposed to the content and other relevant actors to identify and distinguish the AI system’s artificially generated content from other content. A technical solution is to be understood as a combination of techniques for marking and means for detection that the provider has implemented to fulfil the transparency obligation under Article 50(2) AI Act.

(70) Each of the two above-mentioned elements must be fulfilled to achieve effectively the objectives of the transparency obligations of Article 50(2) AI Act. Fulfilling only one element (e.g. for machine-readable marking of outputs without the means for their detection being available) will not suffice to comply with that provision (27).