Guides · Article 50 · EU AI Act
What is a deepfake under the EU AI Act?
'Deepfake' is a word people use loosely, but it appears in Article 50(4) of the EU AI Act as the trigger for a specific disclosure duty. This guide gives a plain-language orientation to how the paragraph uses the term. It is informational only and not legal advice. Importantly, this is not the Act's formal definition — the Regulation defines its terms elsewhere — and whether a given output is a 'deep fake' is a fact-specific question for qualified counsel.
How Article 50(4) uses the term
In plain terms, Article 50(4) addresses AI systems that generate or manipulate image, audio, or video content that constitutes a deep fake, and it places a disclosure duty on the deployer of such a system: to disclose that the content has been artificially generated or manipulated (Article 50(4), Regulation (EU) 2024/1689). The everyday intuition — realistic-looking media produced or altered by AI that could be taken for genuine — is a reasonable orientation, but it is not a substitute for the Regulation's own defined meaning.
Note the role: the deepfake disclosure duty sits with the deployer, not the provider. That is the opposite allocation from the synthetic-content marking duty in 50(2), which falls on the provider.
The modulations built into the paragraph
The regulation text limits the obligation where the content forms part of an evidently artistic, creative, satirical, fictional or analogous work or programme — there, disclosure is limited to revealing the existence of the generated or manipulated content in a manner that does not hamper enjoyment of the work. There is also a law-enforcement carve-out. Whether your output is a 'deep fake' and whether a modulation or carve-out applies are all fact-specific.
Common questions
Is this the EU AI Act's official definition of a deepfake?
No. This is a plain-language orientation to how Article 50(4) uses the term. The Regulation sets out its formal definitions elsewhere, and whether a specific output is a 'deep fake' within that meaning is a fact-specific question — confirm with qualified counsel.
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