Guides · Article 50 · EU AI Act
AI email assistants and Article 50
AI email assistants draft replies, suggest phrasing, summarise threads, and clean up tone inside inboxes and CRMs. The Article 50 paragraph most often raised for generated text is 50(2), the provider-side marking of synthetic text — and its editing carve-outs are especially relevant to assistants that polish a message a user is already writing. This guide explains the text and the carve-outs from the regulation. It is informational only, not legal advice, and does not name any tool category as in or out of scope.
Marking synthetic text — 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. As written, any duty sits on the provider of the email system, not on every sender who accepts a suggestion. A private one-to-one email is not text 'published with the purpose of informing the public on matters of public interest', so the text limb of Article 50(4) will often be a poor fit — but whether a given email assistant's output is 'synthetic ... text content' under 50(2) is still a fact-specific question.
The assistive-editing and no-substantial-alteration carve-outs
The paragraph does not apply to the extent the AI systems perform an assistive function for standard editing or do not substantially alter the input data provided by the deployer or the semantics thereof. Much of an email assistant's work — fixing grammar, tightening a sentence, adjusting tone on text the user wrote — can sit close to that language, while generating a full reply from a one-line instruction may look more like synthetic text generation. Whether a given feature 'performs an assistive function for standard editing', or 'does not substantially alter the input data or the semantics thereof', is fact-specific. Document any carve-out reasoning for counsel rather than assuming it.
Common questions
Does an AI email writer have to mark its drafts as AI-generated?
Any Article 50(2) marking duty is written on the provider of the system, and the paragraph carves out to the extent a system performs assistive standard editing or does not substantially alter the input. Whether an email assistant's output is in scope and whether the carve-out fits are 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.