Is machine-translated content "AI-generated" under the EU AI Act?

From August 2, 2026, Article 50 of the EU AI Act requires AI-generated content to be identifiable as such. Whether a machine translation of human-written text counts as "AI-generated" is one of the questions the Act never answers explicitly, and for anyone running a localized website or app it is the question that decides whether these rules apply to them at all.

The honest answer as of June 2026: the Act's text is ambiguous, but the European Commission's draft guidance points to yes. And the same guidance describes an exemption path that a well-run translation review workflow already satisfies.

This is not legal advice. This article summarizes public legal texts and guidance for orientation. The draft guidelines cited here are not final. For decisions about your own obligations, consult a qualified lawyer.

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What Article 50 actually requires

Article 50 of the AI Act (Regulation (EU) 2024/1689) contains two separate obligations that matter for content, and they fall on different actors:

1. Machine-readable marking, on the AI system provider. Article 50(2) requires that providers of AI systems generating synthetic audio, image, video or text content

"ensure that the outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated."

This is watermarking and metadata, not a visible banner. It is the obligation of whoever provides the AI system (the MT engine, the LLM), and it explicitly does not apply

"to the extent the AI systems perform an assistive function for standard editing or do not substantially alter the input data provided by the deployer or the semantics thereof."

Keep that exception in mind. It is where the whole machine-translation question lives.

2. Visible disclosure, on the deployer. Article 50(4), for text, requires that deployers of an AI system

"that generates or manipulates text which is published with the purpose of informing the public on matters of public interest shall disclose that the text has been artificially generated or manipulated."

This one is a visible label, but its scope is narrow (more on that below), and it has the exemption this article is ultimately about.

The dates, including the Omnibus trap

If you saw May 2026 headlines saying "the EU delayed the AI Act": the delay is real, but it is about high-risk systems. The part relevant to content and translation teams was not delayed.

The Omnibus changes are a provisional political agreement (May 2026) still awaiting formal adoption, as law firm briefings like Gibson Dunn's summary note. The August 2, 2026 date for Article 50 is not part of those changes: it stands in the Act as adopted. Non-compliance can be fined with up to EUR 15 million or 3% of total worldwide annual turnover, whichever is higher.

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Is machine translation "AI-generated"? The unresolved question

Here is the genuinely interesting legal question. Machine translation does not create content from nothing: a human wrote the source text, the AI only moves it into another language. Is the result "artificially generated or manipulated" content?

The case for "no"

The strongest argument that machine translation falls outside Article 50(2) is the Act's own exception, quoted above: systems that "do not substantially alter the input data provided by the deployer or the semantics thereof" are exempt from marking. A faithful translation is, by definition, meaning-preserving. If the semantics survive the language transfer intact, the argument goes, the output is the deployer's human-authored content in a different surface form, not synthetic content. Translation tools also long predate generative AI, and nothing in the Act's recitals singles them out.

The case for "yes"

The counter-argument: every sentence an MT system outputs is text the model generated. Word choice, register, sentence structure, terminology: all of it is model output, and all of it can be wrong in ways that change meaning. A translation is not an edit of the source text; it is new text in a language the source never existed in.

This is the reading the European Commission has now taken, at least in draft. The draft guidelines on the Article 50 transparency obligations, published May 8, 2026, list as their very first example of "semantic changes that require marking under Article 50(2) AI Act":

"AI-generated translations and summaries of text"

while grammar correction and spell-checking stay safely in the exempt "standard editing" bucket. So under the draft guidance, AI translation is not the meaning-preserving assistive edit of the "no" reading; it is a substantial alteration that the system's provider must mark.

Where that leaves you

Three caveats keep this from being settled:

• The guidelines are draft and non-binding. The targeted consultation closed on June 3, 2026, and the final version may shift (several industry responses pushed back on exactly this point, as briefings like Covington's 10 takeaways document).
• Even if translation counts, the marking duty in Article 50(2) sits with the AI system's provider, not with the company using MT for its website. As a deployer your direct exposure is Article 50(4).
• And Article 50(4) is narrow. The disclosure duty only covers text "published with the purpose of informing the public on matters of public interest": think public health information, safety guidance, reporting on political or economic developments, investor information. The draft guidelines explicitly exclude fiction, entertainment, and ordinary advertising (unless it makes health, safety or sustainability claims). Most localized UI strings and product copy never enter its scope.

So the precise question "is MT output AI-generated text?" remains formally unresolved until the guidelines are final and, eventually, courts weigh in. A useful summary of the obligations is the Article 50 text and the practical guide on artificialintelligenceact.eu. But you do not need the question resolved to be safe, because of the exemption.

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The exemption that matters: human review and editorial responsibility

Article 50(4) does not apply, verbatim,

"where the AI-generated content has undergone a process of human review or editorial control and where a natural or legal person holds editorial responsibility for the publication of the content."

The draft guidelines construe this narrowly, and the wording is worth reading closely. Human review means

"the deliberate examination of the substance of the content by one or more natural persons possessing relevant competence and professional judgement pertaining to the subject matter under scrutiny."

And explicitly not:

"Superficial, solely formal or procedural checks (e.g. spell-checking or grammatical correction), the mere existence of an editorial policy or cursory editorial approval without substantive engagement by the human reviewer or the editorial entity, cannot fulfil the conditions for human review or editorial control."

In short: the checks must be substantive, not limited to superficial matters or cursory approval. The second condition, editorial responsibility, means a named natural or legal person holds ultimate responsibility for the publication, and the guidelines expect their identity and contact details to be publicly findable (a website's legal notice or terms is given as an example).

What the guidelines effectively demand is not a feeling of having reviewed things, but a documented editorial workflow with identified responsible persons. If a regulator asks, "this went through human review" needs to be demonstrable: who reviewed it, what they could change, who approved publication.

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How to be safe under either reading

This is the practical part, and it is shorter than the legal part, because the two readings of the MT question converge on the same to-do list:

1. Route machine and AI translations through human review. Not necessarily all of them; review where it matters and where confidence is low (see below).
2. Make the review substantive. Reviewers need competence in the language and the subject matter, and the authority to approve, change, or reject the translation. A rubber-stamp click does not meet the bar the draft guidelines set.
3. Record who reviewed and approved what, and when. The exemption is only worth something if you can show the process happened.
4. Name who holds editorial responsibility for published content, and make that publicly findable (legal notice, terms, colophon).
5. Ask your MT/AI providers about machine-readable marking. Under Article 50(2) that part is their obligation, including for translation output if the draft guidance holds.

The logic is deliberately either-way:

• If machine translation does count as AI-generated text, your reviewed content sits squarely in the human-review exemption, and no "AI-generated" disclosure is required.
• If it does not count, or your content never falls under Article 50(4)'s narrow public-interest scope, you have lost nothing: the same workflow is simply how you catch the mistranslations that were going to embarrass you anyway.

Compliance pressure and translation quality point at the same workflow. That is rare, and worth using.

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Where Locize fits

Locize is built around exactly the workflow the exemption path needs:

• The review workflow turns translations into pending proposals that a human reviewer with the right permissions must accept or reject: deliberate, substantive engagement, per segment.
• Quality Estimation scores every AI translation with a confidence estimate, and the Review AI workflow routes low-confidence translations into review automatically. Your reviewers' substantive attention goes where the AI is least sure, instead of being spread thin across everything. (Background in the Quality Estimation announcement.)
• The history of every segment records when and how each translation changed and who changed or approved it, so "this went through human review" is something you can show, not just assert. The provenance export packages this evidence in one action, per version, language or namespace: a report as CSV and JSON listing who reviewed or approved each translation and when, the AI confidence score at the moment of the decision, what is still pending review, and a summary header so the file stands on its own in front of an auditor.
• User management lets you give reviewers and approvers distinct roles, which maps cleanly onto "identified responsible persons".

To be clear, and in the spirit of the disclaimer above: no tool makes you compliant with the AI Act, and Locize does not either. What it gives you is the documented, substantive, person-attributable review process that the Article 50(4) exemption asks for, working ahead of guidance that is still being finalized.

If you want your translation workflow on that footing before August 2, 2026: create a free Locize account and enable the review workflow and Quality Estimation for your languages. The step-by-step setup, including the provenance export and what each review status means for an auditor, is documented in Running an Article 50(4)-compatible review workflow in Locize.

The question in the title may stay unresolved for a while. Your answer to it does not have to.