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Jurisdiction · European Union

EU AI Act · Article 50.

Article 50 addresses transparency for certain AI systems and generated content. Provider marking duties and deployer disclosure duties are distinct; consent to a likeness does not replace either obligation.

Source checked · 6 September 2026 · implementation assessment pending

European Commission: Article 50 guidance, timing and exceptions

What it requires

  1. 01Article 50(2): Providers of generative AI systems must mark outputs in a machine-readable format that they are AI-generated.
  2. 02Article 50(4): Deployers must disclose AI-generated or manipulated deepfakes. Whether content qualifies depends on its resemblance, apparent authenticity and context; special rules apply to evidently artistic or fictional works.
  3. 03The disclosure must be clear, distinguishable, and presented at the latest at the time of first interaction.
  4. 04Deployment must comply with EU GDPR for any biometric data processing (see /compliance/gdpr).
  5. 05Penalties up to €15M or 3% of global annual turnover for breaches of Article 50.

Current implementation and gaps

  1. 01Every Mirai output is generated against a recorded consent chain: the underlying generator, the consenting model, the licensing brand, the prompt version, and hashes of the reference images are stored server-side at generation time. Embedding this as a machine-readable C2PA content-credential manifest in the image file itself is in progress, it has not shipped yet, and we do not claim Article 50(2) marking is complete today.
  2. 02Where Article 50 applies, brands using Mirai imagery in EU campaigns are contractually required to disclose that the content is AI-generated. The visible 'Made with Mirai · Licensed Talent' badge (light and dark SVG variants on request from info@mirai.inc) is a compliance aid to help meet the disclosure-at-first-interaction requirement; it is not a safe harbour, and brands remain responsible for their own compliance.
  3. 03Public licence verification pages are available for issued platform licences. A licence record confirms recorded usage rights; it does not prove that a circulating file is unaltered or carries a valid embedded Content Credential. Supporting records can be requested from info@mirai.inc, subject to privacy and access restrictions.
  4. 04Mirai's Brand Acceptable-Use Policy explicitly requires EU deployers to comply with Article 50 disclosure obligations as a contractual term. We reserve the right to suspend brand accounts that knowingly bypass disclosure.
  5. 05We do not claim that Mirai is certified compliant with Article 50. Marking, disclosure and the applicable provider and deployer responsibilities need to be assessed for the actual workflow before use in a regulated campaign.

Current C2PA and provenance status is tracked publicly in the trust center.

What this means for brands

If you run campaigns into the EU using Mirai imagery, the upstream consent chain is recorded server-side at generation time and every unlicensed image carries a visible Mirai watermark. Machine-readable Article 50(2) marking is in progress. A visible label does not replace an applicable machine-readable marking obligation, and embedded metadata alone does not replace an applicable audience-facing disclosure. Confirm the requirements and implementation with your legal team before publishing an EU campaign.

We do not provide legal advice. For our Article 50 compliance framework and the current status of our DPA program, email info@mirai.inc.