How do I apply Article 50(4) of the AI Act to the content of a Drupal site?
This article is not legal advice. It sets out what Regulation (EU) 2024/1689 and the European Commission FAQ say, and what the module does with those rules. Whether a piece of content needs a label is up to whoever publishes it.
What AI Disclosure is and how it is built is covered on the project page. This article looks only at how the module turns Article 50(4) into data and into a label on the page.
How does AI Disclosure decide whether content needs a label?
AI Disclosure keeps two things apart: how much AI went into the content, and whether the rule applies to that content at all.
The first is the grade, one of nine. Six grades say that AI generated or manipulated what was published: translation, summary, partial rewrite, text written with a person leading, text written with nobody leading, deep fake. The question about the rule only makes sense for those six. The other three, meaning no AI, metadata picked by AI and content rated by AI, stay out of it.
The second is the set of four scope answers:
| Question | What it decides |
|---|---|
| Is it a deep fake in image, audio or video, or is it text? | which of the two rules in Article 50(4) applies |
| Is it part of an evidently artistic, satirical or fictional work? | for deep fakes, how the label may be shown |
| Is it published to inform the public? | for text, the first condition |
| Does it deal with matters of public interest? | for text, the second condition |
Each answer is yes, no or not assessed. The module infers none of them, neither from the content type nor from the grade.
What does Article 50(4) of the AI Act require?
Article 50(4) sets two separate obligations for publishers, each with its own trigger.
The first covers images, audio and video that make up a deep fake: whoever puts them out must disclose that they were artificially generated or manipulated. Human review does not remove the obligation. When the deep fake is part of an evidently artistic, creative, satirical or fictional work, the duty shrinks to disclosing that generated or manipulated content is there, in a way that does not get in the way of the work.
The second covers text generated or manipulated with AI and published to inform the public on matters of public interest. This one has an exemption, and it needs two conditions at once: the text went through human review or editorial control, and a natural or legal person holds editorial responsibility for it. The Commission FAQ defines editorial responsibility as holding the ultimate legal responsibility for the publication.
Since when does Article 50 of the AI Act apply?
Article 50 has applied since 2 August 2026, the general date set by Article 113 of the Regulation. Content generated before that date does not have to be labelled retroactively. The Commission encourages deployers to do it where possible.
Regulation (EU) 2026/1744, the Digital Omnibus on AI published in the Official Journal on 24 July 2026, left that date alone for publishers. It added a paragraph to Article 111 that applies to providers only: generative systems placed on the market before 2 August 2026 must comply with Article 50(2), the marking of the file itself, by 2 December 2026. That is the date often quoted as a general postponement. Article 50(4) is not among the amendments, so publishers are still on the August date.
What does "not assessed" mean in the verdict?
The AI Disclosure verdict has three values: label required, not required, not assessed. A single no on any condition settles the matter even when other answers are missing, and the same holds for the text exemption. "Not assessed" only appears when a missing answer would have changed the outcome.
On the page, content that has not been assessed still shows the disclosure card, with its own wording and a dashed border. Hiding the card would tell readers that no label is due, which is exactly what the site has not yet decided.
How do you answer once for a whole content type?
Answers live on the profile, and every piece of content inherits the default profile of its type. Individual content only steps in for exceptions. Grade and scope answers always come from the same level: the module does not mix answers taken from different levels.
A profile that claims human review without naming who is responsible cannot be saved, neither from the form nor through a configuration import.
On this site the editorial_default profile, set up on 20 September 2026, declares text, published to inform, with human review and a named person responsible.
The profile answers no to the public interest question, and that is my own call, not a fact. The Commission FAQ counts as public interest any economic, financial, political, scientific or cultural development that may become a subject of public debate, and a technical article about the AI Act could fall inside that. The verdict would not change: with a yes, human review and a named responsible person still trigger the exemption.
With these answers the verdict is "not required", and the page says so in its meta tag:
<meta name="ai-disclosure" content="ai_assisted_hitl; required=not-required; icon=ai_modified">The card is still shown, because the site policy is set to "Always disclose AI involvement".
What happens when a label is required?
When a label is required, the official EU icon and the grade sentence appear, and the site cannot hide them. Card visibility is configurable, but a required label always renders. The rest of the card, meaning the legal line, the description and the link to the editorial policy, follows the site settings.
What happens if I change the grade configuration?
Content that inherits its settings reads grade and profile from configuration at the moment it is displayed. Changing the sentence of a grade therefore changes what every piece of content using it shows, including pages published months earlier. The Audit submodule is there for that reason: on every save it copies into its log what the grade meant at that moment, and later configuration changes do not rewrite that record.
What does AI Disclosure not do?
AI Disclosure does not decide whether content needs a label, and it does not check the answers. It accepts whatever name is entered as the editorially responsible person without judging it, and a generic role such as "the editorial team" will not hold up in an audit. It does not mark the file: the JSON-LD is a page-level signal, and the marking required by Article 50(2) is a job for the provider of the AI system, not for the publisher.
Sources and references
All sources were consulted on 27 September 2026.
- Regulation (EU) 2024/1689, Official Journal text (opens in a new tab), EUR-Lex. Article 50(4), and Article 113 on the date of application. Read from the rendered page, primary source.
- Regulation (EU) 2026/1744, Digital Omnibus on AI (opens in a new tab), EUR-Lex, Official Journal of 24 July 2026. Point 39 adds paragraph 4 to Article 111, setting 2 December 2026 for Article 50(2). Within Article 50 only paragraph 7 is amended. Read from the rendered page, primary source.
- FAQ on the transparency obligations under Article 50 (opens in a new tab), European Commission, last updated 24 July 2026. The three criteria for text, the areas of public interest, what counts as human review, editorial responsibility, 2 December 2026 limited to Article 50(2), and retroactive labelling. Read from the rendered page, primary source.
- AI Disclosure project page (opens in a new tab), drupal.org. Release 1.0.0-alpha2 of 12 September 2026, for Drupal 10.4 and 11. Read from the rendered page.
- AI Disclosure documentation on Article 50 (opens in a new tab), page "Article 50, and what this module does not do", updated on 11 September 2026. Primary source on how the module behaves.
- AI Disclosure Module Adds Article 50 Labelling Tools for Drupal (opens in a new tab), The Drop Times, 16 September 2026. News of the two alpha releases and of what the module does. Read from the rendered page.
- The meta tag quoted in the profile section is the one this very page writes in its
<head>. You can check it by viewing the page source.
This content was produced by AI and edited by a person.
How was AI used?
Drafts are produced with AI assistance and then directed, edited and fact checked by a person. Figures, dates and version numbers are verified against their public sources before publication, and the date of that check is stated in the text.
