How to add AI disclosures that comply with the EU AI Act

The EU AI Act’s transparency obligations under Article 50 apply from 2 August 2026 — and if you publish AI-generated content professionally, you have specific disclosure duties that go well beyond adding a footnote to your terms and conditions. The European Commission has published draft guidelines explaining exactly what those disclosures must look like, where they must appear, and what will not meet the standard. This guide translates those requirements into practical placement guidance for content creators, freelancers, and science communicators.

Note: The guidelines referenced throughout this post are a draft published for stakeholder consultation. They do not prejudge the final version, which will be adopted by the Commission. The legal source is Article 50 of Regulation (EU) 2024/1689 (the AI Act).

Does Article 50(4) of the EU AI Act apply to your content?

Article 50(4) creates two distinct obligations depending on what you publish. The first applies to deep fakes — AI-generated or manipulated image, audio, or video content that resembles existing persons, objects, places, or events and would falsely appear to a person to be authentic or truthful. The second applies to AI-generated or manipulated text published with the purpose of informing the public on matters of public interest.

For science communicators and content creators, the text obligation is the most relevant. The Guidelines describe “matters of public interest” as covering topics relevant to society at large — including public health, environmental protection, consumer safety, and scientific, political, or cultural developments with potentially important public implications. The list is explicitly non-exhaustive.

The Guidelines provide examples of in-scope content: an AI-generated summary of a newspaper article on a town council decision; an AI-manipulated academic paper comparing the effects of diets on a disease; an AI-generated message on a meteorological institute’s social media profile warning citizens about stormy weather. Out of scope: AI-generated fictional novels or poems, AI-manipulated advertisement text (unless it contains health, safety, or sustainability claims), and AI news summaries delivered by a chatbot only to the user who prompted it.

If your content explains research findings, covers public health, reports on policy, or addresses environmental topics for a public audience, it almost certainly falls within the scope of Article 50(4)(2).

Freelancers and science communicators: you are likely a deployer

The AI Act distinguishes between providers (those who develop AI systems) and deployers (those who use them to produce content). If you use an AI tool to generate or manipulate content that you then publish, you are a deployer — and Article 50(4) addresses you.

The “purely personal, non-professional” exemption in Article 2(10) of the AI Act does not apply if you earn income from your content on a regular basis, or if you are involved in a freelance, occupational, trade, or business activity. The Guidelines state this directly: any activity through which a natural person gains economic benefit on a regular basis is a professional activity, and freelancers are named explicitly.

Science communicators working under institutional affiliation — even part-time or on contract — also fall within scope. Their work is professional and typically informs the public on matters of public interest. The personal use exemption applies to things like, as the Guidelines illustrate, AI-generated Christmas cards sent to relatives — not to published professional content.

What a compliant AI disclosure must include under Article 50(5)

Article 50(5) sets the horizontal requirements that apply to every disclosure under Article 50(1)–(4). The information must be provided in a clear and distinguishable manner and at the latest at the time of the first interaction or exposure.

“Clear” means noticeable and easy to understand, including for persons with accessibility needs. “Distinguishable” means easy to identify as separate from other information and the surrounding environment. Both conditions must be met simultaneously — a disclosure that is technically present but visually merged with body text or buried below the fold does not satisfy the standard.

For text content, “first exposure” means at the start of the publication — at the moment a reader first encounters it. The Guidelines state explicitly that disclosure placed at the end of a piece does not comply with Article 50(5). For video, the same applies: disclosure at the start, not in the end credits.

What does not count as an AI disclosure under the EU AI Act

The Guidelines are specific about what fails the standard. None of the following, on their own, satisfy the obligation:

• Disclosures contained only in your terms and conditions, a linked URL, or supporting documentation — these may complement an in-content disclosure but cannot replace it
• Machine-readable markings such as metadata or watermarks that are not perceivable by users without technical tools
• Unclear or ambiguous signals, including generic references to “assistant” or vague language about using technology
• Technical descriptions alone — stating that your content “uses LLMs” or was “created with generative AI” without disclosing the artificial origin of the specific content in front of the reader
• Information hidden under layers of menu options on your website or platform

For live broadcasts, the Guidelines note that a one-time disclosure at the start may not be sufficient if viewers can join midway — in those cases, periodic or persistent disclosure is needed throughout.

Where to place your AI disclosure: blog posts, social media, video and podcasts

Blog posts: Place the disclosure visibly at the top of the article, before the first paragraph of content. This is the point of first exposure for your reader. A disclosure at the end of a long post does not meet the requirement, regardless of how detailed it is.

Social media posts: Place the disclosure at the beginning of the caption or post text, before any substantive content. The Guidelines confirm that AI-generated posts on matters of public interest — such as public safety warnings on a social media profile — are in scope. The disclosure must appear before the reader reaches the content, not after it.

Video content: Display a visible text label or overlay at the start of the video, before your substantive content begins. The Guidelines explicitly state that disclosure “as part of end credits does not comply with Article 50(5) AI Act.” For live-streamed content, include periodic on-screen reminders, since a single disclosure at the start is likely insufficient for viewers who join after the broadcast has begun.

Podcast show notes: Place the disclosure at the top of the show notes or episode description page, before the episode summary. If AI-generated content features in the spoken episode itself, a spoken disclosure at the start of the recording is the appropriate equivalent — the same logic of first exposure applies to audio.

The editorial responsibility exception: do you qualify?

Article 50(4) subparagraph 2 includes an exception: if the AI-generated text has undergone human review or editorial control, and a natural or legal person holds editorial responsibility for the publication, the disclosure obligation does not apply to that text.

Both conditions must be met. “Human review” means the deliberate examination of the substance of the content by someone with relevant competence and professional judgement — not a spell-check, not a cursory read-through, and not review by another AI system. “Editorial responsibility” means a specific person or entity holds the ultimate legal responsibility over what is published, and their identity and contact details must be publicly available — for example on a website’s terms and conditions page or in a publication’s colophon.

The Guidelines are direct about what does not qualify: superficial or procedural checks, the mere existence of an editorial policy, and cursory approval without substantive engagement. If you write, lightly review, and publish your own AI-assisted content as a solo creator, the exception is unlikely to apply to you.

Copy-paste AI disclosure templates for every content type

The following templates are based on the legal language in Article 50(4) of the AI Act and the Commission’s draft Guidelines. They are not officially prescribed wording — the Guidelines do not mandate specific phrasing. They reflect the core requirement: that the content has been artificially generated or manipulated, stated clearly at the point of first exposure.

Blog post — fully AI-generated:

This article contains content that has been artificially generated or manipulated using AI tools.

Blog post — AI-assisted (partial):

Parts of this article were artificially generated or manipulated using AI tools.

Social media post (start of caption):

[AI-generated] This post contains text that has been artificially generated using AI.

Video (on-screen text overlay at the start):

This video contains content that has been artificially generated or manipulated using AI.

Podcast — spoken disclosure (start of episode):

This episode contains content that was artificially generated or manipulated using AI tools.

Podcast show notes (top of description):

Note: These show notes contain content that has been artificially generated or manipulated using AI.

Adapt the wording to your context as needed, provided the disclosure remains clear, distinguishable, and placed before your substantive content. Do not move it to end credits, footers, or linked policy pages.

What you can do before August 2026

The transparency obligations under Article 50 apply from 2 August 2026 — and they apply to all in-scope AI systems and content in use at that date, not only to content created after it.

Auditing your existing content now gives you time to build disclosure into your standard publishing workflow before the deadline. It also gives you the opportunity to assess whether any of your content could qualify for the editorial responsibility exception — and to put genuine substantive review processes in place if it does.

Three actions to take now: identify which of your regular content types fall within the scope of Article 50(4); add a disclosure statement to your blog post, video, and social media publishing templates; and assess your editorial process honestly against the standard the Guidelines set — a light read-through before pressing publish is not enough.

Related reading on The Science Talk

This guide accompanies the EU AI Act Article 4 explainer on The Science Talk — which covers the AI literacy obligations that research institutes must meet, providing useful context for science communicators working within institutional settings.

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