Proposal for the EU Transparency License for AI-Generated Content (ETL-AI) ver. 6.1

Legal rationale

The License builds upon the legal foundations set out in Recitals (133)–(135) of the AI Act, which recognise the growing difficulty of distinguishing synthetic from human-created content and the resulting risks of misinformation, manipulation, and loss of public trust. In this context, the ETL-AI offers a normative bridge between law and technology by:

• Defining clear obligations for providers and deployers to apply a verifiable Sign at the moment of creation or first publication;
• Ensuring that the Sign and its metadata qualify as lawful transparency mechanisms consistent with the AI Act, the Digital Services Act, the GDPR, and EU copyright and information-society legislation;
• Enabling voluntary, yet standardised, adoption through an open-license model compatible with future Union Codes of Practice.

Technical implementation

The License specifies a layered approach combining visual, audio, and metadata Signs. These are designed to be:

• Machine-readable and interoperable, allowing automated verification across platforms;
• Human-perceptible, so that users can easily recognise AI-generated material;
• Resilient, surviving common file conversions, re-encoding, and reposting;
• Open and verifiable, using cryptographic identifiers and public-key signatures, without reliance on proprietary infrastructure.

This technical architecture supports existing standards for provenance and content authenticity, while remaining light, scalable, and adaptable to diverse media formats.

Expected benefits for the Union’s internal market

By introducing a single, open, and easily adoptable transparency framework, the ETL-AI strengthens legal certainty and reduces compliance costs for all actors—providers, deployers, and intermediaries alike. It facilitates interoperability among platforms, enhances user trust, and promotes the free circulation of authentic digital information within the internal market. For citizens, it makes transparency visible and meaningful; for businesses, it ensures a level playing field based on fairness, accountability, and innovation.

Together, these measures transform Article 50 from a legislative obligation into a practical European standard, reinforcing the Union’s leadership in trustworthy and human-centred AI.

You are welcomed to submit your comments or contributions to the proposed European Transparency License (ETL-AI) by email at: info@claims.fi