EU AI Act Article 50: short answers for agencies and brands
September 2026
Drafted with AI assistance. Reviewed and approved by Ridwanul (Ray) Kabir, who holds editorial responsibility for this note.
Does Article 50 apply to UK companies?
Yes, if the content reaches people in the EU. The duty follows the audience, so a UK agency whose client’s ads run in Ireland is covered. Where the company is registered makes no difference.
When did it start?
2 August 2026, for businesses that publish AI-made content. Some duties on the makers of AI tools phase in later.
What counts as a deep fake?
An AI-made or AI-altered picture or recording that resembles a real person, object, place or event and could be taken for real. It isn’t limited to faces, and product imagery can qualify.
Do all AI-generated ads need a label?
No. Many don’t, and working out which do is most of the job. The answer depends on what the AI changed and when the asset first went live, among other things.
Who is responsible, the agency or the brand?
Whoever publishes the content. In agency work that comes down to the contract, and most contracts signed before August 2026 say nothing about it.
Is AI-written text covered?
Only text published to inform the public on matters of public interest. It’s exempt where a named person has reviewed it and taken editorial responsibility for it, which is how this note is published.
What does the label have to look like?
The Code of Practice specifies the letters, their proportions, where the label sits and when it has to be visible. Our labelling page shows a label built to it, next to the mistakes we see most.
Does a label make AI content legal?
No. The Code says labelling doesn’t exempt anyone from other obligations. Consent from the people depicted still applies, and so do rights in the material.
What is the fine?
Up to €15 million or 3% of worldwide annual turnover, whichever is higher, under Article 99(4). Each EU country’s regulator enforces it.
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