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The AI Transparency Gap: What Happens Between Supplier and Publisher?

Understanding what it requires is harder than identifying an AI tool and finding a rule that mentions it.

4 Minutes

The EU AI Act is in force.1 Understanding what it requires is harder than identifying an AI tool and finding a rule that mentions it. Obligations depend on how a system is developed, supplied, operated, and used.2 Exceptions can turn on details such as what a person reviewed and which version was ultimately published.3 The European Commission has issued guidance, but each organization must still apply the Act to its own facts.4 

That assessment has two parts. First, an organization must understand its own role. The Act defines a provider and a deployer by what each does, and different duties follow from those roles.5 Second, it must understand its place in the wider workflow. A supplier may operate an AI tool, a client may choose how to use it, a specialist may review its output, and someone else may publish the result. Each stakeholder controls a different decision.6 

One aspect of the EU AI Act is Article 50’s Transparency rules. 
They show why both parts matter and place distinct duties on providers and deployers concerning certain AI-generated content.7 The difficulty often arises when content moves between them. 

One job, several decisions 

Imagine a client orders content through a language service provider’s AI-enabled platform. The client chooses a service tier without specialist review. The supplier processes the job and delivers the text. Weeks later, the client considers publishing it to inform the public about a health matter.8 

The supplier knows how the text was produced. The client knows where it will appear, why it will be published, and whether it has changed since delivery. Neither may have the full picture. Yet the client’s publication assessment may depend on facts held by both.9 

Now suppose the client selected a tier with specialist review. That changes the questions, but it does not answer them automatically. Article 50(4) includes an exception for certain published text that has undergone human review or editorial control and for which a person or organization holds editorial responsibility.10 The Commission says the review must address the substance of the content.11 A quick spell check will not do.12 The parties also need to know whether the published version is the one that was reviewed.13 

Article 50(2) addresses machine-readable marking and detectability by providers of certain AI systems that generate synthetic content, subject to its conditions and exceptions.14 Article 50(4) addresses disclosure by deployers when AI-generated or manipulated text is published to inform the public on matters of public interest, again subject to exceptions.15 Provider marking does not automatically satisfy a deployer’s disclosure duty.16 Nor does every use or publication of AI-assisted text trigger that duty.17 

The eventual publisher’s decisions matter. So do the supplier’s. Assigning responsibility for publication does not, by itself, settle whether the supplier has obligations of its own.18 

A contract cannot rewrite the workflow 

Contracts should say who selects the AI service, who operates it, what review is included, and who controls later use and publication.19 An order screen can capture a client’s choice between reviewed and unreviewed output. A delivery record can identify what review actually took place. 

Those details are more useful than a clause simply declaring the client the “sole deployer.” Legal status depends on conduct, not the label the parties choose.20 An indemnity may allocate risk between them, but it cannot erase an obligation that applies under the Act.21 This follows from the Act’s role definitions and its separate duties for providers and deployers. 

Make the handoff count

The supplier may never know whether a delivered file stays private or becomes a public notice. The client may not know enough about the file’s production and review to make a sound publication decision. This is where transparency can quietly break down. 

A useful handoff gives the client the facts the supplier has: the service tier selected, the AI-enabled processing used, whether substantive review occurred, and which version was reviewed and delivered. The client can then assess its intended publication and document its decision.22 If the intended use changes, the parties have a basis for a conversation rather than competing assumptions. 

That is the larger lesson of Article 50 for a shared content workflow. Know your own obligations. Know which decisions belong to the other stakeholders. Pass along the facts they need. Transparency is most effective when it travels with the content.23 

References 

This article discusses general compliance considerations; a particular service requires assessment of its actual design and operation. 

  1.  Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744; Art. 113.  ↩︎
  2. Art. 2(1), Art. 3(3), Art. 3(4).  ↩︎
  3. Art. 50(4), second subparagraph; Guidelines, points 134–136.  ↩︎
  4. Commission Guidelines C(2026) 5054 final, 20 July 2026; Commission FAQ on Article 50. ↩︎
  5.  Art. 3(3), Art. 3(4); Guidelines, points 10–13. ↩︎
  6.  Guidelines, points 12, 14–17. ↩︎
  7. Art. 50(1)–(5); Recitals 132–134. ↩︎
  8. Art. 50(4), second subparagraph; Guidelines, points 131, 154. ↩︎
  9. Guidelines, points 12, 14, 15. ↩︎
  10. Art. 50(4), second subparagraph; Guidelines, points 133, 138.  ↩︎
  11. Guidelines, point 134; Commission FAQ on Article 50. ↩︎
  12. Guidelines, point 135. ↩︎
  13. Guidelines, point 136.  ↩︎
  14. Art. 50(2), Art. 111(4); Recital 133; Guidelines, points 89–93. ↩︎
  15.  Art. 50(4), second subparagraph, Art. 50(5); Recital 134; Guidelines, points 130–139.  ↩︎
  16. Art. 50(2), Art. 50(4); Guidelines, points 15, 132. ↩︎
  17. Guidelines, point 131. ↩︎
  18. Art. 50(2); Guidelines, points 11, 12, 15. ↩︎
  19.  Guidelines, point 12. ↩︎
  20. Art. 3(3), Art. 3(4); Guidelines, points 12, 17.  ↩︎
  21. Art. 99(4)(g); Art. 113. ↩︎
  22. Art. 50(5); Guidelines, point 138. ↩︎
  23. Art. 50(7); Guidelines, points 12, 16; Code of Practice on Transparency of AI-Generated Content (June 2026).  ↩︎