Do we watermark thumbnails?

Article 50(2) talks about the outputs of the system. If the thumbnail is a generated image, mark it. If it is a non-generated poster frame, do not invent a mark.

Is a style-transfer filter “standard editing”?

The 50(2) exception is for an assistive function for standard editing that does not substantially alter the input data or its semantics. A filter that replaces a face or invents a background is not standard editing. A brightness slider is.

Labeling AI-generated images, audio, and video

Image, audio, and video generators are the cleanest Article 50(2) case: the output is synthetic, and the provider must mark it as machine-readable. If a deployer then publishes a deepfake, Article 50(4) adds a human-readable disclosure. The 2 December 2026 date is only a transition for 50(2) on systems that were already on the market before 2 August 2026.

Educational resource only — not legal advice. scm.cc publishes a readiness report and engineering gap analysis for AI features. It does not give legal advice, represent you before a regulator, or state that a product is ready to ship under any law. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.

Last checked against official sources: 2026-10-11.

Provider work

Mark every export path — in-app preview, download, API, share link. A mark that exists only in your database is not a mark on the output. The official text allows for technical feasibility; it does not allow “we will add it next quarter” for a system you placed on the market after 2 August 2026.

Deployer work

If your customers publish the media, give them a default visible label and a way to mark artistic / satirical context. If you operate a public feed, you are often the deployer as well as the provider. See the deepfake page for the 50(4) exceptions.

AB 2013 sits beside the label

A generative image service made available to Californians also needs the § 3111 website documentation if you are the developer and the system was released or substantially modified on or after 1 January 2022. The label in the UI does not replace that post.

Questions teams ask

Do we watermark thumbnails?: Article 50(2) talks about the outputs of the system. If the thumbnail is a generated image, mark it. If it is a non-generated poster frame, do not invent a mark.
Is a style-transfer filter “standard editing”?: The 50(2) exception is for an assistive function for standard editing that does not substantially alter the input data or its semantics. A filter that replaces a face or invents a background is not standard editing. A brightness slider is.

Back to the AI law hub

Primary sources

Official text wins. Last checked 2026-10-11. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.