Transparency obligations under Article 50 of the AI Act (Regulation (EU) 2024/1689)
As of July 2026 · transparency obligations applicable from 2 August 2026
With effect from 2 August 2026, the transparency obligations of the AI Act (Regulation (EU) 2024/1689) – the "AI Act" – apply to AI-generated and AI-manipulated content. This document explains, in general terms, the transparency obligations that arise for the localisation methods offered by Dubly.AI and which obligations fall on the deployer, that is, the publishing party.
Dubly.AI's role. Dubly.AI provides a technology platform and optional transparency features, such as a watermarking option. The selection and activation of those features, and the compliant labelling and publication of the content created, are your sole responsibility. Dubly.AI does not apply any statutory labelling on your behalf and gives no warranty in this respect. This document is provided for general information only and does not constitute legal advice.
1. Principle: two sets of obligations
Article 50 of the AI Act distinguishes between two addressees:
Machine-readable marking (Art. 50(2)). Providers of AI systems that generate synthetic audio, image or video content must ensure that the outputs are marked in a machine-readable format as artificially generated or manipulated (for example by watermark or metadata). This obligation is addressed to the provider. Dubly.AI makes optional features available for this purpose.
Visible disclosure of deepfakes (Art. 50(4)). The deployer of an AI system that generates or manipulates a deepfake must disclose that the content has been artificially generated or manipulated, in a manner perceptible to the audience. This obligation falls on the publishing party – as a rule, you – and not on Dubly.AI.
A data subject's consent to the use of their voice and likeness concerns personality rights and data protection only. It does not affect the transparency obligations under the AI Act; the two matters are to be assessed separately.
2. What is a deepfake?
Under the AI Act, a deepfake is AI-generated or manipulated image, audio or video content that depicts existing persons, objects, places or events and is capable of creating an impression of authenticity, even though it has been artificially generated or altered.
Important: classification as a deepfake is not a prohibition. Such content may be created and published; there is merely an obligation to label it, on publication, as artificially generated or manipulated. Prohibitions of certain AI practices are governed not by Article 50 but by Article 5 of the AI Act, and the localisation methods addressed here do not fall within them.
3. When is visible disclosure required?
Whether visible disclosure is required depends on whether the content constitutes a deepfake in the above sense. By way of general guidance:
Disclosure is, as a rule, required where a real, identifiable person is reproduced, or their image or voice is altered such that the content is capable of creating an impression of authenticity.
Disclosure is, as a rule, not required where the content does not reproduce a real person and remains recognisable as artificial localisation or translation, or where AI-generated text is reviewed as to its substance, before publication, by a person who holds editorial responsibility for it.
In borderline cases, the position should be weighed on a case-by-case basis; in case of doubt, disclosure is recommended.
The assessment of the specific individual case is always decisive.
4. Notes on labelling in practice
Where disclosure is to be made, it should, in line with the European Commission's interpretative guidance, be apparent already on first contact with the content, clearly worded and not concealed in ancillary notices. In particular, the following are appropriate:
a plain-language notice, for example "This recording was localised using artificial intelligence";
a notice shown at the outset or displayed persistently, not solely in a legal footer;
for audio-only content, an audible form of disclosure;
for evidently artistic or fictional works, a restrained form that does not impair the perception of the work.
5. Legal notice and disclaimer
This document reflects Dubly.AI's current, non-binding understanding, does not constitute legal advice and does not create any advisory or contractual relationship. The assessments set out relate to the general case, cannot replace an assessment of the individual case and are subject to further developments in administrative practice, European Commission guidance and case law. No warranty is given as to accuracy, completeness or currency, to the extent permitted by law; this document creates no contractual assurances or guarantees. Dubly.AI provides technology and optional features only and does not carry out any statutory labelling of content. Compliance with the transparency and labelling obligations – in particular the visible disclosure under Art. 50(4) – rests with the publishing party. For the legal assessment of an individual case, obtaining your own legal advice is recommended.
Legal basis: Regulation (EU) 2024/1689 (AI Act), Article 50, together with the European Commission's guidance issued in relation thereto (2026).