Editorial referenceLast reviewed 17 September 2026
EU AI Act Compliance

Article 50(2) ยท Guidelines and Code

The EU Code of Practice for marking AI-generated content

Last reviewed 17 September 2026. European Commission Guidelines on Article 50 and the Code of Practice on Transparency of AI-Generated Content (final text, June 2026). Last change: Final Code of Practice published, 10 June 2026.

Guidelines and Code

The Commission's Guidelines interpret each paragraph. The Code of Practice, final in June 2026, sets out how signatories implement 50(2): a layered mark.

LayerWhat it carriesOn transformation
Signed metadata

Provenance assertions, typically a manifest

Lost on re-encode or re-upload without metadata preservation

Imperceptible watermark

A signal embedded in pixels, samples or tokens

Depends on technique and transformation; vendors publish own tests

Fingerprint or other detection

A reference computed from the content, or a classifier

Needs a registry or model; nothing is embedded

Free detectionSignatories offer detection of their own marks free of charge to the public.
2 February 2027Date for an interoperable detection solution across signatories.
Public listThe Commission publishes the list of signatories.
Guidelines and Code in fullEuropean Commission
Guidelines

The Commission's Guidelines interpret the scope of each paragraph of Article 50, including what counts as "obvious" for paragraph 1, the assistive-editing and non-substantial-alteration exceptions in paragraph 2, and the treatment of content generated in real time that is not recorded and where marking is not technically feasible.

Code of Practice (final text published June 2026)

The Code sets out measures that signatories commit to as a means of implementing Article 50(2). As published, it describes a layered approach to marking: signed metadata carrying provenance information, an imperceptible watermark embedded in the content, and, where appropriate, fingerprinting or other detection techniques. It commits signatories to offer detection of their own marks free of charge to the public, and sets a date of 2 February 2027 for an interoperable detection solution across signatories. The Commission publishes the list of signatories.

The three layers

Signed metadata carries provenance assertions attached to the file, typically as a manifest; it is removed when a file is re-encoded or re-uploaded without metadata preservation. An imperceptible watermark is a machine-readable signal embedded in the pixels, samples or tokens; persistence depends on the technique and the transformation, and vendors publish their own test results. A fingerprint or other detection is a reference computed from the content, or a classifier trained to recognise generated content; it requires a registry or a model, and no data is embedded in the content.

Sources: Commission Guidelines on Article 50; Code of Practice on Transparency of AI-Generated Content; Commission FAQ.

Questions

Common questions

What does the EU Code of Practice on AI-generated content require?

It sets out measures signatories commit to as a means of implementing Article 50(2). As published, it describes a layered mark: signed metadata carrying provenance information, an imperceptible watermark embedded in the content and, where appropriate, fingerprinting or other detection techniques.

When was the Code of Practice on Transparency of AI-Generated Content published?

The European Commission published the final text in June 2026. Article 50 obligations apply from 2 August 2026.

Do Code of Practice signatories have to offer free AI detection?

Yes. Signatories commit to offer detection of their own marks free of charge to the public, and the Code sets 2 February 2027 as the date for an interoperable detection solution across signatories. The Commission publishes the list of signatories.

What is the difference between the Article 50 Guidelines and the Code of Practice?

The Commission's Guidelines interpret the scope of each paragraph of Article 50, including what counts as "obvious" under paragraph 1, the exceptions in paragraph 2, and real-time content that is not recorded where marking is not technically feasible. The Code sets out how signatories implement the marking duty in 50(2).

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