Yes — for the public-interest AI-text labelling duty specifically, there's a genuine exemption, but it requires two conditions together, not one.
The editorial exception applies only if: (1) a competent human substantively reviews the text — not a spell-check or a rubber stamp — and (2) a named person or entity holds identifiable editorial responsibility for it, typically via an imprint or colophon. Both conditions must be true; meeting only one doesn't get you the exemption.
This matters because it's easy to over-claim: running AI-drafted text past a quick skim before publishing isn't "substantive" review in the sense the guidelines mean, and content with no named responsible person or entity doesn't qualify even if it was carefully reviewed. If you rely on this exemption, document the actual review workflow — who reviewed what, and when — as your evidence.
There's a separate, related point worth knowing about chatbots specifically: human agent-assist, where AI drafts a reply but a human reviews and sends it, is not covered by the Article 50(1) chatbot disclosure duty at all — that duty is triggered only by fully automated responses. This is a different mechanism from the text-labelling exemption above, but the same underlying idea: genuine human involvement in the final output changes your obligations.
If you can't confidently say both editorial-exception conditions are met for a given piece of text, the safer and cheaper path is usually just to add the label: "This text was generated with artificial intelligence," placed in a fixed, visible position.
A worked example helps make the two-condition test concrete. A company blog post drafted by an AI tool, then rewritten and fact-checked by a named in-house editor whose name appears in the site's colophon, clears both conditions — exempt. The same post, drafted the same way but only skimmed for typos by whoever happens to be free that day, with no named editorial owner anywhere on the site, clears neither — labelling is the safer call.
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