AI-generated content and the EU AI Act labelling duty
The system being classified
You provide a tool that generates synthetic images and text for marketing teams in the EU.
Limited risk — transparency duties
No high-risk category applies, but Article 50 transparency obligations do. These are cheap to fix and expensive to ignore.
This is the classification of the configuration described above, not of your system. One different answer can move it — which is exactly what the comparison further down shows, and what the free assessment settles in about ten minutes.
What produced this verdict
These are the entire inputs. The engine is deterministic, so these answers always produce the verdict above.
Article 50 transparency triggers
- · Generates synthetic audio, image, video or text content
Scope and role
- · Provider — you build it or place it on the market under your name
- · Placed on the EU market, or output used in the EU
What applies, and from when (3)
Every entry cites the article it comes from and the date it binds. That second column is the part most summaries of the Omnibus get wrong.
| Article | Obligation | Binding from |
|---|---|---|
| Art. 4 | AI literacy Ensure staff dealing with AI systems have a sufficient level of AI literacy (training records recommended). | 2 February 2025 |
| Best practice | AI system inventory Maintain a central register of all AI systems in use, their purpose, risk tier and owner. | Good practice |
| Art. 50(2) | Machine-readable content marking Synthetic audio, image, video and text output must be marked as artificially generated in a machine-readable way. | 2 August 2026 |
What would change this verdict
Each row below is the same scenario with one answer changed, re-run through the same engine. These are not predictions about your system; they are what our classifier returns when that single fact differs. Where one change to the scenario necessarily moves a second answer with it, the row says which, and why.
The output is used to screen job applicants
Becomes high-risk systemGeneration is not the question the Act asks. What the output decides is, and worker management is an Annex III category.
- Obligations: 3 → 15 (+12)
- Key date changes to 2 December 2027 — Annex III high-risk obligations apply (postponed from 2 August 2026 by the 2026 Omnibus); Article 50 transparency duties apply already
You also provide the general-purpose model behind it
Same risk tierArticles 53 and 55 attach to the model, not to the interface in front of it.
- Obligations: 3 → 6 (+3)
Your system is not this system
The assessment asks the same questions this page answered for a generic configuration, and produces the verdict, the gap list and the 30-day plan for yours. Ten minutes, free, no sign-up, and it runs entirely in your browser — your answers never reach us.
Classify your own system →Other configurations
Deploying deepfake content triggers Article 50 disclosure duties that are live now, not in 2027. The engine's verdict for an advertiser using synthetic likenesses.
Inferring emotions from workers is an Article 5 prohibited practice, not a high-risk category with a 2027 runway. What that means for a system already in production.
Article 5 bans scoring people by general behaviour where it leads to unjustified detrimental treatment. Where an ordinary customer-scoring system crosses that line.
Annex III point 5(b) covers creditworthiness but expressly excludes AI used to detect financial fraud. The engine's verdict for a fraud system, and where the exclusion stops.
Produced by rule set 1.6.1, legal state 2026-08-05. The engine is deterministic and contains no language model in the verdict path, and every rule is published at /methodology for you to audit.
AnnexWise is preparation software, not legal advice. This page classifies a described configuration; it is not an opinion on any particular organisation or system.