Compliance
EU AI Act Article 50 and AI music disclosure.
In force since 2 August 2026. What it actually requires for audio, who it binds, and what it does not solve.
This is a plain-language summary for people working in music, not legal advice. Take advice from counsel before relying on it.
What Article 50 requires
Article 50(2) requires providers of systems generating synthetic audio, image, video or text to ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, with solutions that are effective, interoperable, robust and reliable as far as is technically feasible.
Article 50(4) separately requires deployers of AI generating audio that constitutes a deep fake to disclose it. The two are not interchangeable.
A transitional period ran to 2 December 2026 for the marking duty, for generative systems placed on the market before 2 August 2026. There is no retroactive labelling of content created before that date.
The two-layer rule
The accompanying Code of Practice, finalised 10 June 2026, is the operative technical guidance. Its central statement is that no single marking technique suffices to meet Article 50(2). It requires at least two layers: digitally signed, time-stamped metadata where the format supports it, and imperceptible watermarking embedded so that it is difficult to separate from the content.
It adds that fingerprinting approaches may be preferable for audio, while stating that relying on fingerprinting or logging alone is not sufficient. Robustness must survive pitch shifting, time stretching, noise, filtering, format change, and what it calls the analogue hole: playback and re-recording.
Key dates
| Article 50 in force | 2 Aug 2026 |
| Code of Practice final | 10 Jun 2026 |
| Transitional period ends | 2 Dec 2026 |
| Maximum penalty | €15M / 3% |
Around 190 organisations signed the Code of Practice, including the largest general AI labs. The major dedicated music generators are not among the signatories, and the largest has announced watermarking without shipping it.
Also in force
California SB 942, operative 2 August 2026. The only US audio-labelling law. Covers audio for systems above one million monthly California users, requires a free public AI-detection tool and a machine-readable provenance watermark.
What the law does not solve
Article 50 binds providers. It does not put a marking obligation on the person who uploads a track, and it does nothing about generators operating outside its reach or about anyone who deliberately strips a mark.
Which leaves the same practical position as before: for the catalogue that already exists, and for anybody not cooperating, acoustic detection is the only mechanism available. The regulation makes provenance more common. It does not make it universal, and universality is what an ingest gate needs.
Common questions
Article 50(2) places its obligation on the providers of generative AI systems, not on you for uploading a track. Article 50(4) separately requires deployers to disclose deep fakes. Your own disclosure obligations are far more likely to come from your distributor or platform contract than from this regulation.
The Code of Practice says no single technique suffices and requires at least two layers: signed metadata where the format supports it, plus an imperceptible watermark that is hard to separate from the content. It notes fingerprinting may be preferable for audio but is not sufficient alone.
Up to 15 million euro or 3% of worldwide annual turnover, whichever is higher, for breaches of the transparency obligations.