Official-source-backed technical resource

Review placement of a synthetic media disclosure

For content assessed as requiring a visible or audible disclosure, test the first exposure in its actual publishing context. Includes a free implementation worksheet.

Short answer

For content assessed as requiring a visible or audible disclosure, test the first exposure in its actual publishing context. Do not rely only on hidden metadata or a separate policy page.

Download the blank working record (.md)

When to use this guide

A realistic synthetic clip has a disclosure in the description, but autoplay begins where the description is collapsed.

This is a fictional implementation scenario. The procedure below is Article 50 Hub's suggested working method, not a prescribed legal form, a customer result or a claim that every step is an additional statutory requirement.

Review procedure

  1. Record the qualified scope decision and the content version it covers.

  2. Map the first exposure on the publishing surface, including autoplay and embeds.

  3. Test the disclosure's visibility or audibility in that state.

  4. Keep evidence of the final published version and any platform limitations.

What the example review finds

  • Autoplay exposes the clip before the description is opened.

  • The embedded version omits the accompanying disclosure.

Keep these example observations separate from your own results. An unknown or untested state should stay open until the relevant evidence has been inspected.

Fields for your working record

  • Content version

  • Scope decision

  • First exposure

  • Disclosure location

  • Published evidence

Use the downloadable blank worksheet linked on this page to connect the observed behavior with the deployed system. Add a reviewer, date, evidence reference, unresolved questions and a next action. The worksheet is editable locally and does not upload your records to Article 50 Hub.

Completion and handoff

Close the task only for the scope actually reviewed. Preserve the result that another authorized reviewer can reproduce, identify the owner of remaining work, and record a retest when the implementation changes. A completed worksheet is not a substitute for the underlying evidence.

Decision boundary

This procedure assumes a scope review; it does not classify every synthetic asset as a deepfake.

The official references below provide legal or technical context. Resolve applicability and exception questions with the responsible qualified reviewer; use the product's tools to organize implementation work within that assessment.

Official sources

  1. EU AI Act — legal text and contextEUR-Lex
  2. Commission FAQ — transparency obligations and scopeEuropean Commission
  3. Article 50 Service Desk — read with its amendment notice and current Commission guidanceEuropean Commission

Last reviewed: 2026-09-23. This is technical implementation information, not legal advice.

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