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Governance & evidence

Transparency and Synthetic Content Marking

Article 50 requires three kinds of disclosure: tell people they are interacting with AI, mark artificially generated content so it can be identified, and disclose deep-fake provenance with a disclaimer. The Transparency register keeps those three notice types in one place, each with a method and optional evidence.

Transcript

Article 50 has three disclosures: tell people they are interacting with AI, mark synthetic content as artificially generated, and disclose deep-fake provenance.

The Transparency register keeps those three notice types in one place, each with a method like watermark, C2PA or metadata, and an optional evidence file.

Previously the Art.50 obligation looked completed as soon as you had a system. Now it requires at least one Transparency record, which is the honest evidence.

Create an interaction disclosure for a chatbot, a synthetic marking with watermark or C2PA for a generator, or a deep-fake disclaimer with a screenshot.

Each notice type is independent. A recommender may need only interaction disclosure, a generative image model likely needs all three.

Why this is required

Three separate spreadsheets or a single 'transparency done' toggle make it hard for an auditor to check which disclosures actually exist. A typed register makes that check straightforward.

Synthetic-content marking needs a method claim (watermark, C2PA provenance, or metadata) plus proof. Storing the method and linking an evidence file makes that proof queryable.

What EuroCompliant does

Each transparency record stores a notice type (AI interaction, synthetic content marking, or deep-fake disclosure), the method used, a description, and an optional evidence file.

Once at least one record exists, the Article 50 obligation is satisfied.

Walking through it

1

Create an interaction disclosure

Notice type interaction_disclosure, method e.g. in-app banner, and where users see it. Link a system if it belongs to a specific AI system.

Open /transparency →
2

Mark synthetic content

Notice type synthetic_marking, method watermark / C2PA / metadata, and the tool or pipeline that applies the mark. Attach a proof file via EvidenceFile where you have a screenshot or sample.

Open /transparency →
3

Disclose a deep fake if you generate one

Notice type deep_fake_disclosure, method disclaimer_screenshot or provenance record, and where the disclosure is shown to recipients.

Open /transparency →

The law

Frequently asked

Why did ai_act_50 previously show as completed before I had documented anything?

The old _has_transparency_notices returned true for any tenant with a system, so ai_act_50 looked completed as soon as you registered a system. It now requires at least one TransparencyRecord, which is the honest evidence for Art.50.

Do I need all three notice types?

Only those that apply to your systems. A non-generative recommender that never creates synthetic content needs interaction_disclosure but not synthetic_marking; a generative image model likely needs all three. The register tracks what you actually have.

Related guides

Try it on your own systems

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