Article 50 policy template
AI generated content labelling policy template
Use this page to assign owners, label placement rules, EU icon decisions, provider marking dependencies, Code signatory status, exceptions, evidence retention, and review cadence for Article 50 labelling workflows.
Educational and operational only. Not legal advice, certification advice, audit assurance, or a compliance guarantee.
Current EU AI Act dates use Regulation (EU) 2026/1744 and the consolidated AI Act. The final voluntary Article 50 Code of Practice, signatory and non signatory evidence routes, EU icon use, and draft high-risk classification guidance are separate implementation materials. The Code can support marking and labelling implementation, but it does not replace binding law, final Commission guidelines, or legal review.
Quick answer
A labelling policy should decide who approves Article 50 labels, where the label appears, whether EU icons are used, which provider marking evidence is required, which exceptions are being relied on, and how the decision is retained. The policy should also record whether the organisation is a Code signatory, is considering signature, is following Code aligned measures, or is using other adequate measures as a non signatory.
Use when
- AI generated or manipulated content may reach users or the public.
- Deepfake, synthetic media, chatbot, or public-interest text scenarios appear.
- Marketing, product, support, legal, or compliance teams need one approval path.
Do not use as
- A legal opinion.
- Proof of Article 50 compliance.
- A replacement for vendor evidence.
- A substitute for review by qualified counsel where the use is material.
Evidence output
- Approved label wording.
- Placement and timing record.
- EU icon decision.
- Provider marking dependency.
- Reviewer and next review date.
Policy decision table
| Policy field | Decision to record | Evidence to retain |
|---|---|---|
| Scope trigger | Direct AI interaction, synthetic content, emotion recognition, biometric categorisation, deepfake, or public-interest text. | System name, content channel, user exposure point, and Article 50 scenario. |
| Provider marking dependency | Whether provider machine readable marking or detection is available, relied on, absent, or unclear. | Vendor documentation, provenance setting, watermark or metadata evidence, and date requested. |
| Human facing label | The wording, placement, timing, accessibility route, and language version of the disclosure. | Approved notice text, screenshot or content sample, reviewer, approval date, and exception record. |
| EU icon decision | Whether an EU icon is used, not used, or under review. | Icon version, accompanying text, placement record, and reason for the decision. |
| Public-interest text review | Whether human review or editorial control applies and who holds editorial responsibility. | Reviewer name, editorial owner, review notes, publication channel, and retained final copy. |
| Code route | Signatory, considering signature, Code aligned, or non signatory adequate measures. | Signatory decision record, alternative-measures rationale, owner, and review trigger. |
| Exception handling | Whether an artistic, creative, satirical, fictional, analogous, authorised by law, or editorial control exception is being used. | Exception basis, approver, reason, and legal review flag where needed. |
| Retention and review | Where the record is stored and when it must be reviewed again. | Repository path, retention owner, next review date, and change trigger. |
Minimum policy sections
- Purpose and legal boundary.
- Covered systems and content channels.
- Roles and approval authority.
- Provider marking evidence requirements.
- Human facing label rules.
- EU icon decision rule.
- Public-interest text review and editorial responsibility.
- Exceptions and escalation.
- Retention, review, and change triggers.
Related Article 50 tools
- Article 50 Transparency Guide
Use before deciding whether a label or disclosure is likely needed.
- Article 50 Code versus law guide
Separate voluntary Code measures from binding Article 50 obligations.
- Article 50 notice templates
Draft notice wording after the policy owner and scenario are clear.
Common questions
Use these questions to separate the policy template from legal proof, icon use, and Code signatory records.
No. The template is an operational starting point for internal policy records. Article 50 decisions should be confirmed with qualified counsel or the relevant authority where needed.
No. The European Commission says deployers may use the EU icons for certain AI generated or manipulated content, but icon use is optional and does not establish legal compliance by itself.
The signatory decision field records whether the organisation has signed the Article 50 Code, is considering signature, is following Code aligned measures, or is using other adequate measures as a non signatory.
Source and review note
Last reviewed: 2 September 2026. Source basis: Regulation (EU) 2024/1689 as consolidated on 27 July 2026, Regulation (EU) 2026/1744, the final Commission Article 50 guidelines published on 20 July 2026, the voluntary Code of Practice published on 10 June 2026, its adequacy conclusion, the AI Board assessment, and the Commission EU icons page. The Code is voluntary implementation support. Article 50 transparency obligations remain legal obligations where they apply. EU icons are optional labelling aids and do not establish legal compliance by themselves.