Guides · Article 50 · EU AI Act
AI translation tools and Article 50
Machine translation is one of the most established AI text applications, and it raises a distinctive Article 50(2) question: translated output is new text, yet the aim is to preserve the meaning of the source. This guide works through how the provider-side marking duty and its carve-outs read against translation, from the regulation text. It is informational only, not legal advice, and does not name any tool category as in or out of scope.
Article 50(2) and translated text
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 here sits on the provider of the translation system, not on every user who pastes in a paragraph. Whether translated output is 'synthetic ... text content' inside the meaning of the paragraph is a fact-specific question the regulation does not settle on its face.
The 'does not substantially alter the semantics' carve-out
The paragraph carves the obligation back: it 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 an interesting fit for that language, since a faithful translation is intended to carry the source's semantics into another language rather than change them — though it plainly alters the input words. Whether a given translation feature 'does not substantially alter ... the semantics thereof', or performs an assistive function for standard editing, is fact-specific and not something to assume — a literal sentence-for-sentence translation may sit differently from a tool that localises, adapts, or rewrites content for a new audience. If you intend to rely on the carve-out, document the reasoning and confirm it with qualified counsel. Article 50(5) would still govern the timing and accessibility of any disclosure that does apply.
Common questions
Does AI translation output have to be marked as AI-generated?
Any Article 50(2) marking duty is written on the provider of the translation system, and the paragraph carves out to the extent a system does not substantially alter the input data or its semantics or performs assistive standard editing. Whether translated text 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.