Regulation (EU) 2024/1689
Meet the Article 50(2) marking duty before 2 December
What Article 50 requires, who it covers and the deadlines, mapped to the Verda feature that meets each duty.
Am I in scope of 50(2)?
From Art. 50(2) and the Guidelines. Indicative, not legal advice.
The 30-second answer
Art. 50 and the Code of PracticeWho is covered
Providers
Of systems generating synthetic audio, image, video or text, including general-purpose models.
Art. 50(2)
What you must ship
- A machine-readable mark in every output
- Detection, free to the public
- A C2PA manifest alongside the mark
Art. 50(2); Code 1.1, Commitment 2
Deadlines
- 2 Aug 2026New systems mark
- 2 Dec 2026Systems already on the market
- 2 Feb 2027Interoperable detection
Not covered by a mark
50(1), 50(4)
AI interaction notices and deep-fake disclosure are separate duties.
Verda covers 50(2) and both Code layers with one API: watermark plus C2PA manifest, and free detection.
Compare vendorsTimeline
New systems mark now. Older ones by 2 December.
Article 50 applies. New systems must mark.
Grace period running
Systems already on the market must mark
Interoperable detection among Code signatories
Sources: Reg. (EU) 2024/1689 Art. 113; 2026 amendment package; Code of Practice (June 2026). Neutral reference: euaiactcompliance.org.
Three tiers, one watermark
The law asks for the first layer only
Keep them separate to defend exactly what you claim.
ComplianceRequired
A machine-readable, detectable AI-generated signal, with free public detection.
SourceArt. 50(2); Code Measure 1.1 and Commitment 2
ProvenanceCalifornia
Provider, system version, timestamp and unique ID, resolvable from the mark.
SourceCalifornia SB 942; Code Measure 2.3. Not Art. 50(2)
IdentityOptional
A verified organization, agent or creator behind the record.
SourceNo statute. Verda offers it; most vendors do not
Detail on each tier
The law requires the first tier. Provenance and identity are what make a mark useful to a platform, a regulator or a fraud team, and what the California statute and the Code of Practice reach for.
Provenance is required by the California SB 942 latent disclosure, which since SB 1000 also states whether the system created or altered the content; it is described in Code Measure 2.3 and not required by Art. 50(2).
Identity is useful for agent authorization, brand protection and fraud response. It is required by no statute and recognised via digital signatures in AB 853. Verda offers this tier; most vendors do not.
The playbook, by task
Checklist, exemptions and vendors
Each on its own page, with the detail and common questions.
Eight steps for providers
Mark at generation, attach a C2PA manifest, offer free detection, test, document. A checklist you can tick, with the detail for each step.
Open the checklist → Exemption test · Art. 50(2)Narrow ways out
Assistive editing, output authorised for criminal-offence work and the real-time carve-out, against what keeps you in scope.
Run the exemption test → Vendors comparedWhat each vendor says about itself
Verda, SynthID, Adobe Content Authenticity and Meta AudioSeal / Video Seal on eight criteria, from each company's public site.
Compare vendors →Deployer checklist
What the person sees
For organisations using a generating system under their own authority.
A watermark does not discharge these duties.They are about what the person sees.
- Art. 50(4)
- Art. 50(4)
- Art. 50(5)
- Code; SB 942 licensee duty if applicable
- Art. 50(1)
0 of 5 done
Full detail
Deep fakes: image, audio or video that resembles real people, places or events must be disclosed as generated or manipulated, with the artistic-work variation. The disclosure must be delivered at first exposure, clear, distinguishable and conforming to accessibility requirements. Do not strip metadata or re-encode in ways that remove marking; check with your provider what survives your pipeline. Voice agents: an audible "you are speaking with an AI agent from [company]" at the start of the call.
Marking approaches compared
Why the Code asks for two layers
Manifests are stripped on re-upload. The watermark persists.
Full comparison table
| Approach | What it carries | Survives re-encode and re-upload | Survives crop, screenshot, telephony | Proves origin | Meets Art. 50(2) alone |
|---|---|---|---|---|---|
| Signed metadata (C2PA) | Rich, signed assertions | No, stripped by most platforms | No | Yes, cryptographically, while present | Only while present; the Code pairs it with a watermark |
| Visible label | A human-readable notice | Depends on placement | Cropped out | No | No, it is not machine-readable in the sense used |
| Fingerprinting | Nothing embedded; lookup by content hash | Partially | Partially | Only against a registry you control | Not on its own; requires registry access |
| Classifier detection | Nothing embedded; a model guesses | n/a | n/a | No | No; it is not a mark |
| Imperceptible watermark | A small payload embedded in the signal | Designed to; varies by vendor | Designed to; varies by vendor | With a payload and a resolver | Yes, when detectable and detection is offered |
| Verda: watermark plus C2PA manifest | Payload in the signal, manifest in the file | Watermark persists after the manifest is stripped | Designed to survive all three | Provider record and optional verified identity | Designed to meet 50(2) and both Code layers |
FAQ
Questions buyers ask
Does Article 50 require identifying the provider or a person in the mark?
No. Article 50(2) requires machine-readable marking and detectability. Provider fields are a California SB 942 requirement, and verified identity is required by no statute. Verda offers both as optional tiers on the same watermark.
Does a watermark make us compliant?
A watermark is the technical control for the 50(2) duty. Deployer disclosure duties under 50(1) and 50(4), documentation, and the Code's free-detection and interoperability commitments are separate. The checklists above cover them.
We are a voice-agent company. Is a live call exempt?
Only if the audio is not recorded and marking is not technically feasible. Most business calls are recorded by at least one party, and real-time audio marking is feasible; the exemption rarely applies. Say the disclosure out loud and mark the audio.
Is a C2PA manifest enough on its own?
The Code of Practice describes metadata and an imperceptible watermark as two layers because manifests are routinely stripped on re-upload. Ship both.
What happens on 2 December 2026?
The grace period for systems already on the market before 2 August 2026 ends; those systems must mark under 50(2) from that date.