Guides · Article 50 · EU AI Act
Disclosure for synthetic and cloned voices
Voice synthesis and cloning power narration, IVR systems, dubbing, and accessibility tools — and can also mimic a specific person's voice. Two EU AI Act paragraphs can bear on synthetic audio: Article 50(2), the provider-side marking of generated audio, and Article 50(4), the deployer-side disclosure where cloned audio of a real person constitutes a deep fake. This guide explains both from the regulation text. It is informational only, not legal advice, and does not name any voice tool as in or out of scope.
Marking synthetic audio — 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, taking into account the specificities and limitations of the content type. Audio has its own robustness constraints, which the paragraph expressly acknowledges. This marking duty is written on the provider of the voice system. Whether a given voice generator falls inside 50(2) is fact-specific.
Cloned voices of real people — Article 50(4)
Where the output is audio content constituting a deep fake — for example a convincing clone of an identifiable person's voice — Article 50(4) is written on the deployer: they must disclose that the content has been artificially generated or manipulated. Cloning a real, identifiable voice therefore raises a deployer-side disclosure question that a generic synthetic narrator may not. The artistic-work modulation and the law-enforcement carve-out can apply. Whether your audio is a 'deep fake' and whether a carve-out applies are fact-specific questions for counsel.
What teams tend to separate out
- Whether the audio is synthetic (points toward the provider-side 50(2) marking question).
- Whether it clones an identifiable real person (points toward the deployer-side 50(4) question).
- Who is provider-side and who is deployer-side for the voice system.
- Timing and accessibility of any disclosure under Article 50(5).
- Counsel's review of the role and scope mapping.
Common questions
Does cloning someone's voice with AI require a disclosure?
Article 50(4) is written on the deployer to disclose deepfake audio as artificially generated or manipulated, and the provider-side marking duty in 50(2) can also apply to synthetic audio. Whether your specific use is a 'deep fake' and how the carve-outs apply 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.