Guides · Article 50 · EU AI Act
AI summary tools and EU AI Act disclosure
AI summary tools condense documents, meetings, or threads into shorter text. Because the output is generated text, Article 50(2) of the EU AI Act is the paragraph to examine — but summarisation also sits close to the carve-outs for assistive editing and output that does not substantially alter the input. This guide explains both sides. It is informational only, not legal advice, and does not determine whether the Act applies to your tool.
Article 50(2) and generated text
Article 50(2) provides that providers of AI systems generating synthetic audio, image, video or text content must ensure the outputs are marked in a machine-readable format and detectable as artificially generated or manipulated (Regulation (EU) 2024/1689). A summariser produces text, so the paragraph is the natural one to test against, and the duty — if it applies — sits on the provider of the summarisation system rather than the end user.
Where the carve-outs come in
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." Summarisation is interesting here: it plainly shortens the input, but a faithful summary can be argued to preserve the source's semantics rather than alter them, and a summary is often positioned as an assistive function. At the same time, a summary that reframes or editorialises may look less like standard editing. Whether a given summary tool falls inside the paragraph, and whether either carve-out applies, are fact-specific — a point to analyse with counsel, not to assume.
A note on where the summary is used
If a summary is published to inform the public on matters of public interest, a different limb — the AI-generated-text provision in Article 50(4), which sits on deployers — may become relevant instead of or alongside 50(2), subject to its own human-review and editorial-responsibility carve-out. Which paragraph governs depends on the system, the role you play, and the use. Confirm the mapping with qualified counsel; our free scope check gives an informational starting point.
Common questions
Does an AI meeting-summary feature need a label?
Article 50(2) addresses providers of systems generating synthetic text, subject to carve-outs for assistive standard editing or output that does not substantially alter the input. Whether a summariser falls inside the paragraph is fact-specific — confirm 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.