Article 50 Check · by Ninth Harbor

Is C2PA required?

No

No. C2PA / Content Credentials is one accepted approach among several for the machine-readable marking duty under Article 50(2) — it is not legally mandated, and no specific technical standard is, as of this writing.

The underlying rule requires providers of generative systems to ensure outputs are marked in a machine-readable way and are detectable, using techniques that are "effective, interoperable, robust and reliable as far as technically feasible." The Code of Practice names categories of accepted technique — watermarking, metadata/provenance records, cryptographic methods, logging, and fingerprinting — and recommends combining them, since no single technique suffices on its own. It does not endorse specific products, and no vendor tool "makes you compliant" by itself.

It's also worth checking whether this duty applies to you at all before worrying about which technique to use. It's a provider duty: it applies only if you develop and offer, under your own brand, a system whose purpose is generating audio, image, video, or text output for others. Merely using someone else's generative AI inside your product — which describes most SMEs — does not trigger it. Most buyers of compliance products in this space don't actually carry this duty.

If you do carry it: prefer inheriting your upstream model provider's marking where it exists, but get written confirmation of what exactly it embeds, and verify it survives your own pipeline (compression, resizing, format conversion, and CDN transforms are common places marking gets silently stripped). Document your reasoning, not just your tooling — the four statutory criteria are assessed holistically.

It's also worth knowing which edits do and don't need marking at all, since not every AI-touched output is treated the same way. Grammar and spell-check, noise reduction, and minor crops are exempt as assistive standard editing. Translations, summaries, object removal or insertion, background changes, and colorization, by contrast, must be marked — so a translated version of AI-generated marketing copy can trigger the duty even where the original English version, reviewed by a human, would not.

Not sure how this applies to your specific setup? The free 2-minute check tells you which of the four Article 50 duty areas likely apply to your company — no email required.

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