Guides · Article 50 · EU AI Act
AI translation and EU AI Act disclosure
Machine translation turns text in one language into text in another, which raises a genuine question under Article 50 of the EU AI Act: is a translation "synthetic ... text content" that needs marking, or does the carve-out for output that does not substantially alter the semantics apply? This is one of the harder edge cases, and the honest answer is that it is fact-specific. This guide lays out the tension. It is informational only, not legal advice.
Why Article 50(2) is the paragraph in view
Article 50(2) addresses providers of AI systems generating synthetic audio, image, video or text content, requiring the outputs be marked in a machine-readable format and detectable as artificially generated or manipulated (Regulation (EU) 2024/1689). A translation engine produces text as output, so on its face the paragraph is the relevant one to test against — and, being a provider-side duty, it would fall on the party that develops or offers the translation system.
The semantics carve-out is squarely relevant
The same paragraph provides that the obligation 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." Translation is often argued to preserve, rather than alter, the meaning of the source text — the very thing the carve-out describes. Whether a given translation feature falls within that carve-out is a fact-specific reading: a faithful rendering and a heavily rewritten or summarised localisation are not obviously the same. This guide does not decide the point; it flags that the carve-out is directly in play and should be analysed, not assumed in either direction.
How to handle the uncertainty
Because reasonable readings differ, the practical step is to describe what your translation feature does to the source — a straight translation, a paraphrase, a creative localisation — and analyse the carve-out against that description with qualified counsel, documenting the reasoning either way. Our free scope check can help frame whether Article 50(2) is worth examining for your system; it does not resolve the carve-out question for you.
Common questions
Is a machine translation 'AI-generated content' that needs marking?
Article 50(2) covers providers of systems generating synthetic text, but carves out output that does not substantially alter the input's semantics — which translation may or may not do depending on the facts. It is a fact-specific question to work through 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.