# Article 50 publication decision worksheet

BTW working aid · 6 September 2026
Not a prescribed legal form, an automated classification or proof of compliance. Use current official scope guidance and the actual publication context. Unknowns remain unknown.

## Fictional worked record

This demonstrates how to record an unresolved assessment, not a legal conclusion about a real film.

- Asset: GLASS-film-v04.mp4
- Organisation/role: Example Studio, using an AI system for a client film; recorded role = deployer
- Publication: client's public campaign page; separate social cut planned
- Generated content: a realistic generated shot of an existing public building
- Scope question: could the presentation falsely appear to show an authentic event? Reviewer has not completed the assessment.
- Artistic treatment: fictional film context recorded; applicability and appropriate manner of disclosure still to be assessed
- Provider marking: tool's marking information retained separately; not treated as the studio's audience disclosure
- Proposed disclosure: opening notice on the campaign page; exact wording and placement unresolved
- First-exposure check: page embed and social cut must be reviewed separately; an end credit alone is not assumed sufficient
- Decision owner: Example Producer; publication reviewer to be named
- Status: assessment incomplete / notice not published
- Next action: resolve scope and publication treatment with the responsible reviewer, then check the actual release and retain its evidence

## Blank working record

- Organisation / role / responsible person:
- Exact asset filename / version / publication date:
- What was generated or manipulated:
- Provider marking information retained:
- Planned publication channel / first audience exposure:
- Image, audio or video: deep-fake scope assessment and reasons:
- Text: public-interest purpose; human review/editorial control and editorial responsibility assessment:
- Applicable exception or artistic adaptation, if any, and reasons:
- Assessment outcome: applies / does not apply / unresolved:
- Decision owner / date / unresolved questions:
- Proposed disclosure wording / placement / timing / accessibility:
- Actual published disclosure / release version / evidence location:
- What differs for other channels or edits:
- Next owner / action before release:

An internal record and an audience-facing disclosure are different outputs. Preserve the reasoning and what was actually published; a saved decision does not establish compliance. Reassess a changed publication context rather than carrying a label decision across automatically.

## Official references

- Scope and exceptions: https://digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations
- Voluntary implementation code: https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content
- Regulation, Article 50: https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng

Guide: https://behindtheworkflow.ai/guides/eu-ai-act-article-50-creative-teams