EU AI transparency duties now apply
EU AI Act Article 50 has applied since August 2, 2026. Professional AI users can be deployers and must clearly disclose deepfakes and certain AI-generated or manipulated public-interest text unless qualifying substantive human review or editorial control applies.
Published 2/8/2026
What happened?
Article 50 began applying on August 2, 2026. The European Commission says regular economically beneficial freelance activity is professional use and can make an individual a deployer. Deployers must disclose deepfakes clearly by first exposure and label AI-generated or manipulated text published to inform the public on matters of public interest unless it receives substantive human review or editorial control. Spelling or grammar checks alone do not qualify.
Why it matters
Freelance writers, designers, marketers, and video producers serving EU audiences may be deployers or may operate a client’s system under the client’s responsibility. Deliverables involving realistic synthetic media or public-interest text therefore need explicit ownership of classification, review, disclosure, approval, and evidence.
What should you do?
Add an AI-content checkpoint to briefs and sign-off: identify EU exposure and deployer responsibility, classify deepfakes and public-interest text, place a visible or audible disclosure where required, preserve available provenance, and record substantive review. Assign review and labelling responsibility in the contract.