EU AI Act Article 50Verda playbook Verda API

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.

1Does your system generate audio, image, video or text, or change the meaning of existing content?
2Is it only assistive standard editing, such as crop or noise reduction, with no substantial change?
3Is the output real-time, unrecorded and not technically feasible to mark?
Answer to see your result.

The 30-second answer

Art. 50 and the Code of Practice

Who is covered

Providers

Of systems generating synthetic audio, image, video or text, including general-purpose models.

Art. 50(2)

What you must ship

  1. A machine-readable mark in every output
  2. Detection, free to the public
  3. A C2PA manifest alongside the mark

Art. 50(2); Code 1.1, Commitment 2

Deadlines

  1. 2 Aug 2026New systems mark
  2. 2 Dec 2026Systems already on the market
  3. 2 Feb 2027Interoperable detection

Full timeline

Not covered by a mark

50(1), 50(4)

AI interaction notices and deep-fake disclosure are separate duties.

Deployer checklist

Verda covers 50(2) and both Code layers with one API: watermark plus C2PA manifest, and free detection.

Compare vendors
01

Timeline

New systems mark now. Older ones by 2 December.

  1. Article 50 applies. New systems must mark.

  2. Grace period running

  3. Systems already on the market must mark

  4. Interoperable detection among Code signatories

Sources: Reg. (EU) 2024/1689 Art. 113; 2026 amendment package; Code of Practice (June 2026). Neutral reference: euaiactcompliance.org.

02

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.

04

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.

05

Marking approaches compared

Why the Code asks for two layers

Manifests are stripped on re-upload. The watermark persists.

At encodeAfter re-uploadAfter crop or screenshot
C2PA manifestPresentStripped by most platformsNo
Verda watermarkEmbeddedPersistsDesigned to survive
Full comparison table
ApproachWhat it carriesSurvives re-encode and re-uploadSurvives crop, screenshot, telephonyProves originMeets Art. 50(2) alone
Signed metadata (C2PA)Rich, signed assertionsNo, stripped by most platformsNoYes, cryptographically, while presentOnly while present; the Code pairs it with a watermark
Visible labelA human-readable noticeDepends on placementCropped outNoNo, it is not machine-readable in the sense used
FingerprintingNothing embedded; lookup by content hashPartiallyPartiallyOnly against a registry you controlNot on its own; requires registry access
Classifier detectionNothing embedded; a model guessesn/an/aNoNo; it is not a mark
Imperceptible watermarkA small payload embedded in the signalDesigned to; varies by vendorDesigned to; varies by vendorWith a payload and a resolverYes, when detectable and detection is offered
Verda: watermark plus C2PA manifestPayload in the signal, manifest in the fileWatermark persists after the manifest is strippedDesigned to survive all threeProvider record and optional verified identityDesigned to meet 50(2) and both Code layers
06

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.

Ship it

Encode in three lines. Verify anywhere, free.