Compliance
AI disclosure moves from policy chat to client work
Guidelines on transparency obligations, AI Act Article 50
What happened
The European Commission published its guidelines on Article 50 of the AI Act, ten days before the transparency duties started on 2 August. The guidelines set out what has to be disclosed when content is generated or altered by AI, and who carries the duty: the provider of the system, and the deployer who puts the output in front of an audience.
Deployer means you. If AI made or altered work that goes out for a European client, the obligation sits with whoever published it, not with the tool that produced it.
What needs disclosing
Disclose synthetic public-facing images, audio, video and text. Research, rewritten drafts, resizes and work that stays inside the agency do not usually require disclosure.
What does not
What does not: Assistive use that does not change the substance: research, drafts a person rewrites, resizes, alt text, and anything that never leaves the agency.
Why it matters here
Large agencies handle this in legal review. A small agency does not have that step. If disclosure lives only in a policy document, it gets remembered on the slow campaigns and forgotten on the ones that go out on a Friday.
The fix is not another policy. It is one line in the campaign brief, filled in at the start, while someone still knows what was used and why. This is not legal advice. On high-value work, check the wording with a lawyer.
Do this by Friday
Add an AI-use and disclosure check to every live campaign brief. Ten minutes per brief, and the account lead owns it.
01
List the live campaigns with European audiences publishing this quarter.
02
Add two fields to the brief: what AI was used for, and whether it needs disclosing.
03
Agree the wording once, cleared with the client, not campaign by campaign.
04
Raise it before the client does. Disclosure they discover is a problem.
Try it now
Here is our campaign brief template and a description of how we used AI on this campaign. Draft the disclosure line we would put in the brief, and the one that would sit next to the published work, in plain English.
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Run it properly
The Client Report Playbook
The full job, stage by stage, if this week’s steps open a bigger conversation.
Members get every briefing four weeks earlier.
They had this one while there was still time to act on it. In AI, a month is a long time: this week’s briefing is already with them.
