Guides · Article 50 · EU AI Act
Disclosure for AI avatar and presenter videos
AI avatar tools turn a script into a video of a synthetic presenter — useful for training, marketing, and localisation. Two EU AI Act paragraphs can bear on such video: Article 50(2), the provider-side marking of synthetic video, and Article 50(4), the deployer-side deepfake disclosure where the video depicts a real person convincingly. This guide explains both from the regulation text. It is informational only, not legal advice, and does not name any avatar tool as in or out of scope.
Marking synthetic video — Article 50(2)
Article 50(2) asks providers of AI 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 effective, interoperable, robust and reliable as far as technically feasible. Video combines image and audio, each with its own limitations, which the paragraph acknowledges. This marking duty is written on the provider of the avatar system. Whether a given tool's video falls inside 50(2) is fact-specific.
Avatars of real people — Article 50(4)
Where an avatar video generates or manipulates content constituting a deep fake — for example a lifelike likeness of an identifiable person — Article 50(4) is written on the deployer to disclose that the content has been artificially generated or manipulated. A fully synthetic, invented presenter sits differently from a digital double of a real individual. Where the video forms part of an evidently artistic, creative, satirical, fictional or analogous work, the obligation is limited to disclosing the existence of generated content in a manner that does not hamper enjoyment of the work. Whether your video is a 'deep fake' and whether a carve-out applies are fact-specific.
Placement and timing
Article 50(5) points toward a clear, distinguishable disclosure at or before first exposure, meeting accessibility requirements. For video, teams commonly consider an on-screen or descriptive note in addition to any provider-side marking carried in the file. The illustrative label 'This video features an AI-generated presenter' is shown only to indicate tone — it is not approved wording and not legal advice.
Common questions
Does an AI presenter video need a disclosure?
The provider-side marking duty in Article 50(2) can apply to synthetic video, and the deployer-side deepfake disclosure in 50(4) can apply where the video depicts a real person convincingly. Which applies to your case, if either, is fact-specific — verify with qualified counsel.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.