# AI disclosure and compliance

> How EU AI Act Article 50 disclosure becomes a lineage query, and the six schema fields that make a per-asset disclosure manifest computable.

Article 50 of the EU AI Act came into force on **2 August 2026**. It requires deployers to disclose AI-generated public-interest content and deepfakes, with penalties reaching EUR 15M or 3% of global turnover.

Disclosing correctly requires knowing, per asset, what is synthetic. That is a lineage question — and no tracker, asset manager, or render manager can answer it, because none of them held the whole chain. OWG holds the lineage as an ordinary by-product of running the work, so the obligation becomes a query rather than a project.

## What the regulation distinguishes

Three distinctions matter, and conflating them is the most common mistake:

| Category | Treatment |
|---|---|
| **AI-generated** — created or substantially altered by AI | Disclosure required |
| **AI-assisted** — standard editing assistance, no substantive semantic alteration | Exempt |
| **Depicts a real person** | Triggers the deepfake provisions |

The exemption is narrower than people hope and wider than they fear. Denoise, up-res, and grammar fixes are assistive. A voice clone, synthetic imagery, AI-written text, or a lip-sync dub is generative.

## The six fields

Disclosure is **declared** at the point of work and **computed** at the point of delivery. Six schema fields carry the declarations:

| Field | Level | Values / purpose | Article |
|---|---|---|---|
| `ai_role` | Task | `generative` \| `assistive` \| `none` | 50(2) |
| `depicts_real_entity` | Asset | Does this depict an identifiable real person? | 50(4) |
| `assurance` | Asset | `attested` (verified credential) \| `asserted` \| `inferred` | — |
| `work_type` | Context | `creative-fictional` \| `factual-news` \| `advertising` \| `sports` \| `other` | 50(4) |
| `editorial_signoff` | Task | Named editor accepting responsibility | 50(4) |
| `disclosure_gate` | Governance | Blocks delivery until certified | 50 |

The critical design choice: **the per-asset conclusion is computed from lineage, not stored.** An asset is synthetic, hybrid, or traditional because of what its ancestry says, not because someone remembered to tick a box on it. Storing the conclusion would let it drift out of agreement with the work that produced it.

### Declaring AI involvement

`ai_role` is declared on the task, and **AI-ness is never inferred from the executor type**. The schema says so explicitly. An `agent` executor might be doing deterministic file shuffling; a `saas_api` executor might be running a diffusion model. Only the explicit declaration is authoritative.

```json
{
  "id": "dub_es_419",
  "type": "work",
  "label": "Spanish (LatAm) lip-sync dub",
  "executor": { "type": "saas_api" },
  "ai_role": "generative",
  "performed_by": "agent_dubber",
  "used": ["master_audio_en", "reference_perf_v2"],
  "produced": ["dub_es_419_v1"]
}
```

```json
{
  "id": "denoise_plate_0140",
  "type": "work",
  "executor": { "type": "local_app" },
  "ai_role": "assistive",
  "performed_by": "a.rivera",
  "used": ["plate_0140_raw"],
  "produced": ["plate_0140_dn"]
}
```

The second is exempt from marking, and the graph records *why* it is exempt rather than leaving the exemption as an undocumented assumption.

### Editorial sign-off

Where the regulation expects a named human to take responsibility, `editorial_signoff` names one. The `editor` field is required within it:

```json
{
  "id": "review_copy_final",
  "type": "review",
  "performed_by": "j.mbeki",
  "editorial_signoff": {
    "editor": "j.mbeki",
    "statement": "Reviewed for factual accuracy; accepts editorial responsibility.",
    "timestamp": "2026-08-19T14:22:00Z"
  }
}
```

A participant with `role: "editor"` is the one eligible to provide it.

### Governance ceilings

Run-level ceilings sit alongside the disclosure gate, which is what makes the gate more than advisory:

```json
{
  "governance": {
    "disclosure_gate": true,
    "max_total_reroutes": 12,
    "budget_usd": 4800
  }
}
```

With `disclosure_gate` set, delivery-typed tasks are **blocked** until the compliance validator certifies the project and emits the disclosure manifest. Compliance stops being a pre-delivery scramble and becomes a condition of delivery.

## The baseline rule pack

The specification defines a **baseline rule pack** — six rules a conformant compliance validator must
implement. Rules are evaluated against a delivery-typed task and the lineage of the assets it
delivers.

| Rule | Check | Severity |
|---|---|---|
| **R1** | A task whose executor can involve AI (`agent`, `saas_api`, `comfyui_graph`, `comfyui_node`) leaves `ai_role` unset | Error |
| **R2** | A delivered asset whose lineage contains a `generative` task carries no disclosure marking | Error |
| **R3** | A delivered asset whose lineage contains both a `generative` task and an asset with `depicts_real_entity: true` carries no deepfake disclosure | Error |
| **R4** | An AI-generated text asset delivered in a `factual-news` context has no `editorial_signoff` by a participant with `role: "editor"` in its lineage | Error |
| **R5** | `governance.disclosure_gate` is true and a `delivery` task completed without a certified manifest asset in its `used[]` | Error |
| **R6** | A disclosure-relevant value (`ai_role`, `depicts_real_entity`) rests on an `inferred` relationship with no `accepted_by` | Warning |

Three of these deserve a note.

**R1 is deliberately conservative.** Silence is not a declaration of innocence. An unset `ai_role`
on a task that *could* involve AI is a finding, not a default of "no AI" — which is why declaring
`ai_role: "none"` explicitly is an [authoring rule](/for-agents#authoring-rules) rather than
optional politeness.

**R3 is independent of `work_type`.** The deepfake provisions attach to depicting a real person,
not to the genre. A synthetic likeness in a drama triggers R3 exactly as one in a news package does.

**R6 is a warning rather than an error**, because an inferred disclosure input is not wrong — it is
unconfirmed. A human accepting it clears the finding, which is the [acceptance record](/relationships#an-inferred-edge-end-to-end)
doing its job. Certifying on an unaccepted inference is a defensible choice; doing it without
knowing you did is not.

### Extending the pack

The baseline is the floor, not the ceiling. Jurisdiction- and client-specific rules are added as a
**versioned pack** layered over it, because obligations differ by territory and regulation keeps
developing — binding every rule into the core would date the specification.

Two requirements on any pack:

- **It must version**, and a certification must record which pack version judged it. When
  regulation changes you need to know what standard a past delivery was held to.
- **It may add and tighten, never remove.** A pack that disables a baseline rule is not conformant.

See [Implementation considerations](/implementation-considerations#compliance-rule-sets) for how to
structure one.

## The deliverable

The output is a **signed, per-asset AI disclosure manifest** — the document a broadcaster can hand a regulator.

It is itself an asset, produced by a task, performed by a responsible participant. Compliance has provenance too: the manifest can answer who generated it, from what graph state, and when. A manifest that could not account for its own origin would be a strange thing to hand a regulator.

## Where OWG sits

Three layers, often conflated:

1. **Creation-time marking** — C2PA content credentials, applied at capture or generation.
2. **Production-time tracking** — the lineage OWG produces as a side effect of running the work. **This is the layer that was missing.**
3. **Publication-time labelling** — the EU icon set, applied at distribution.

Layers 1 and 3 already existed. Without layer 2, an organization can mark at creation and label at publication and still be unable to say which of ten thousand delivered assets needs the label — because nothing tracked the chain in between.