Regulation (EU) 2024/1689 · Art. 50(2)
EU AI Act Article 50 compliance checklist for providers
What a provider of a generating system must ship to meet Article 50(2) and the Code of Practice, step by step, with the Verda feature for each.
Updated 16 October 2026. From Art. 50 of Regulation (EU) 2024/1689, the Commission Guidelines and the Code of Practice (June 2026). A vendor publication by Verda Inc. Not legal advice. Last change: Article 50 applies from today, 2 August 2026.
Provider checklist
Eight steps for providers
- Art. 50(2)
- Art. 50(2); Code 1.1.2
- Code 1.1.1
- Code Commitment 2
- Art. 50(2)
- Code
- Art. 50(2); Art. 99
- Art. 50(1), 50(5)
0 of 8 done
Full detail for each step
- Scope your outputs
- List every modality your system emits (audio, image, video, text) and which are in scope after the exemption test.
- Embed a machine-readable mark at generation
- Mark inside the content, not only in the file container. Verda: encode API in the generation pipeline, image, audio and video.
- Attach signed provenance metadata
- Write a C2PA manifest alongside the mark so both layers of the Code are present. Verda: manifest written at encode.
- Offer free public detection
- Web upload, URL input and an API. Verda: public verifier at verda.ai/verify and a decode API; white-label option.
- Test robustness against the transformations your content meets
- Compression, resizing, cropping, transcoding, screenshots; for audio, codecs and telephony. Publish the method. Verda: results on the benchmarks page. Art. 50(2) "robust and reliable".
- Plan for interoperable detection
- Be able to detect other signatories' marks or route to their detectors by 2 February 2027. Code, interoperability commitment.
- Document the technical solution
- Method, payload, detection thresholds, known limits, versioning. Keep it for the market surveillance authority.
- Write the disclosure for interactive systems
- If people interact with the system directly, tell them at the first interaction, unless it is obvious.
FAQ
Common questions
How do I comply with EU AI Act Article 50(2) as a provider?
Mark every in-scope output in a machine-readable, detectable way at generation, attach signed provenance metadata (a C2PA manifest) alongside the mark, offer free public detection, test robustness and publish the method, plan for interoperable detection by 2 February 2027, and document the technical solution. If people interact with the system directly, tell them at the first interaction, unless it is obvious.
When do providers have to start marking AI-generated content?
New systems must mark from 2 August 2026, when Article 50 applies. Systems already on the market before 2 August 2026 must mark from 2 December 2026. Interoperable detection among Code of Practice signatories follows by 2 February 2027.
How do I test that my AI watermark is robust enough for Article 50(2)?
Article 50(2) asks for marking that is robust and reliable. Test against the transformations your content meets: compression, resizing, cropping, transcoding and screenshots, and for audio, codecs and telephony. Publish the method.
What documentation does a provider need to keep for Article 50?
Document the technical solution: method, payload, detection thresholds, known limits and versioning. Keep it for the market surveillance authority.
More in the playbook
Other sections
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 · Art. 50(4)What the person sees
Deep-fake and public-interest text disclosure at first exposure. A watermark does not discharge these duties.
Deployer checklist → TimelineDeadlines
New systems mark from 2 August 2026, systems already on the market from 2 December 2026, interoperable detection by 2 February 2027.
Full timeline →