Labelling AI written text: what the law asks for
The practical question is who signs it off. The disclosure duty for AI generated text does not apply where the content underwent human review or editorial control and a natural or legal person holds editorial responsibility for the publication. That is one step in your process, recorded once per article.
What the exemption asks for
Two conditions, both written out. The content has to have undergone a process of human review or editorial control, and a natural or legal person has to hold editorial responsibility for the publication.
Neither condition is about wording. They describe a step in how a text reaches the public: somebody read it, somebody corrected it, and somebody answers for it afterwards.
So the compliance question for a business is not which sentence to add. It is who that person is, and whether there is any record that they did the reading.
And the scope stays narrow. The duty attaches to text published to inform the public on matters of public interest, which is your advice articles and commentaries rather than your service descriptions.
What the record looks like
Three fields per published article: who reviewed it, on what date, and what was changed. For a business publishing 2 articles a month that is 24 rows a year and about 1 minute each.
Add the date the obligations began, 2 August 2026, and you have a defensible position for everything published since. Anything published before that is outside the period the obligations cover.
If nobody reviews, the label is required instead. One sentence at the foot of the article stating that the text was produced with AI support is the honest alternative, and it is far cheaper than pretending a review happened.
| Field | Why | Effort |
|---|---|---|
| Reviewer | The exemption names a person | Seconds |
| Date of review | Ties it to the publication | Seconds |
| What was changed | Evidence the review was real | A line |
| Label, where no review | The duty applies instead | One sentence |
Two mistakes to avoid
Do not label everything by default. A notice on pages written by hand devalues the notice, and it invites the question of what else on the site is approximate.
Do not name a reviewer who did not read it. The exemption rests on the review having happened, and a record that says otherwise is worse than no record.
And keep the record where the articles are. A table in the mailbox of somebody who has left the business is not a record in practice, because nobody can open it any more.
Two minutes per article, kept in the same folder as the article itself. That is the entire cost of the exemption, and it is smaller than the cost of arguing about whether it applies.
Questions and answers
Does a review by the author count?
What if nobody reviews the text?
How long should I keep the record?
Does this cover my service pages?
Sources
- EU AI Act, Article 50, transparency obligations The disclosure duty and the editorial control exemption
- EU AI Act, Article 113, entry into application The 2 August 2026 date
