Labelling AI-written text.

Reviewed

Short answer

AI-written text needs a visible label in the EU only when someone using AI professionally publishes it to inform the public on matters of public interest, such as politics, public health or the economy, and no human reviewed it under someone’s editorial responsibility. Internal documents, private correspondence and short texts that convey no knowledge, opinions or facts fall outside that duty, and spell-checking alone does not count as human review.

Official sources: AI Act, Article 50(4), second subparagraph · Commission guidelines on Article 50, section 6.2

The three tests

When AI-generated text falls under Article 50(4)
TestWhat it means in the guidelinesOutside the duty
PublishedAccessible to an indeterminate, fairly large number of unrelated readers, paid or freePrivate messages, a small closed group, internal company networks
Informing the publicCommunicates knowledge, opinions or factsShort texts that do not materially communicate knowledge, opinions or facts
On matters of public interestPolitics and democratic processes, public administration, justice, fundamental rights, public security, public health, environment, consumer safety, and economic, financial, political, scientific or cultural developments open to public debateTopics without that link

All three must be met. Then the deployer must label the text clearly, for example with a visible disclaimer, unless the exception below applies.

The human review exception

No label is needed when the AI text went through human review or editorial control and a natural or legal person holds editorial responsibility for publishing it. The guidelines set a real bar: review means a deliberate examination of the substance by people with relevant knowledge, and fact-checking is the minimum. Spell-checking, grammar fixes, automated review, the mere existence of an editorial policy or a cursory sign-off do not count. If AI changes the substance after the sign-off, the exception is lost.

Examples from the Commission's Article 50 guidelines
TextLabel needed?
An AI-edited newspaper article or AI summary, under the editor-in-chief’s editorial controlNo
An AI-edited academic blog that went through internal peer review, run by a research centreNo
AI-generated public safety warnings approved by an official of the civil protection agencyNo
AI-generated sustainability report reviewed by professionals such as compliance staffNo
An AI translation of a human-written article that a person reviewedNo
A website posting AI-generated articles on EU policy without any deliberate human reviewYes

Who holds editorial responsibility should be easy to find: the guidelines ask that the name and contact details of the responsible person, function or company be public, for example in the legal information of a website or a publication’s colophon.

The provider side: watermarks in text

Separately, providers of text generators must mark their output in a machine-readable way (Article 50(2)). Free-form text cannot carry metadata, so the Code of Practice accepts a single layer for it, an imperceptible watermark, and applies it to free-form text longer than 200 tokens; very short text is excepted. The guidelines also leave out of the marking duty short sequences such as single words or captions, and source code.

Publishing a book

Amazon’s Kindle Direct Publishing asks authors to tell it about AI-generated text, images or translations when they publish or republish a book, even after substantial edits; AI-assisted content (your own text, edited or checked with AI) does not need to be disclosed (KDP content guidelines).

Questions

Do I have to label a blog post written with ChatGPT?
Only if it is published to inform the public on a matter of public interest and nobody reviewed its substance under your editorial responsibility. If you, with relevant knowledge, check its substance and facts and publish it under your own editorial responsibility, with your contact details available, that is the kind of review the Commission’s guidelines describe.
Is AI translation covered?
Yes, if the translated text is published to inform the public on public-interest matters. The guidelines give an AI translation of a human-written article that a person reviewed as an example that does not need a label.

Sources

Last reviewed by Volkan Çatak, Founder, Proofcan.

Not legal advice. This page explains official texts in plain words and links each one; check the sources, or a lawyer, before relying on it for a decision.