Running an Article 50(4)-compatible review workflow in Locize
From August 2, 2026, Article 50 of the EU AI Act requires AI-generated content to be identifiable as such, and the European Commission's draft guidance treats AI translations as content that requires marking. Text that has undergone substantive human review, with a named person holding editorial responsibility, is exempt from the visible disclosure duty of Article 50(4). The legal background, the dates and the open questions are covered in the explainer Is machine-translated content "AI-generated" under the EU AI Act?. This page covers the practical side: how to run that review workflow in Locize and how to document it.
This is not legal advice. This page describes Locize features and a workflow setup for orientation. For decisions about your own obligations, consult a qualified lawyer.
Step 1: enable the review workflow
Enable the review workflow for the languages where review matters to you. Once enabled, changes to translations become pending proposals instead of direct writes, and the actual value only changes when a reviewer accepts a proposal.
Project settings, EDITOR, TM/MT/AI, ORDERING tab, Review Workflow section in the Cat settings card.
Step 2: route low-confidence AI translations into review
With Quality Estimation enabled, every AI translation is scored with a confidence estimate between 0 and 1. The additional Review AI workflow setting routes low-confidence AI translations into review automatically, across all languages, even those without the regular review workflow enabled. High-confidence AI translations are saved directly, so your reviewers' substantive attention goes where the AI is least sure.
Routed proposals carry the confidence score, a critique (accuracy, fluency, terminology, style) and, where possible, a one-click suggested revision.
Step 3: review substantively, with the right roles
The exemption asks for deliberate examination of the substance by people with relevant competence, not a rubber-stamp click. In Locize:
- Give reviewers distinct roles and review permission via user management, scoped to the languages they are competent in.
- Reviewers accept, edit or decline each pending proposal in the editor. Every decision is recorded in the segment history: who decided, when, and for AI proposals the confidence score at the moment of the decision.
Step 4: name editorial responsibility publicly
The second condition of Article 50(4) is that a natural or legal person holds editorial responsibility for the publication, publicly findable. This is not a Locize feature but part of the checklist: name that person or entity in your website's legal notice, terms or colophon.
Step 5: export the evidence (provenance export)
The provenance export packages the review evidence in one download, so "this went through human review" is something you can hand to an auditor.
Where: in the project overview, open the context menu of a version (all languages), a language or a single namespace and choose provenance (CSV + JSON). Available from the Growth plan, like the review workflow (app v2.8.0 and later).
What you get: one ZIP containing the same report as CSV (opens directly in Excel) and JSON (for programmatic use). The file stands alone: a header records the project, version, languages, namespaces, who generated it and when, summary counts per review status, and the known limitations (see below). Each key row lists:
- the current value, its source (HT human, MT machine translation, AI) and its current confidence score
- the last human action: review accepted, review declined, edited, or delivered by a translation service, with who decided, who proposed, when, the value at that moment and the confidence score at decision time
- pending review proposals with proposer, date and confidence
- a
reviewStatusclassification
What reviewStatus means for an auditor:
| Value | Meaning |
|---|---|
pendingReview | Proposals are awaiting a decision. The current value is not yet the reviewed outcome |
humanReviewed | The last human action was a review decision (accept or decline) recorded with the reviewer's identity |
humanEdited | A human edited the value directly, or a translation service delivered it, outside a review decision |
machineOnly | A machine or AI value with no recorded human action |
noHistory | No recorded history for this key: typically a human-sourced value that was never changed, or history that has been trimmed (see limitations) |
Limitations
The export discloses its own limitations in the file header. Mirrored here:
- History is size-bounded. Per namespace, history shares a fixed budget (about 400KB) and is trimmed oldest-first. On very active namespaces, old review events can be trimmed away, and affected keys are reported as
noHistoryrather than guessed. - Confidence scores on older decisions. Review decisions made before app v2.8.0 do not carry the confidence score on the decision itself. For those, the score is reported only while the accepted AI value is still unedited, in which case the current value's score is the at-acceptance score.
FAQ
Q. Does the provenance export make me compliant with the EU AI Act?
A. No tool makes you compliant, and Locize does not either. What the workflow and the export give you is the documented, substantive, person-attributable review process that the Article 50(4) exemption asks for. See the explainer for the legal background.
Q. Who can download the export?
A. Project members with management permissions, on plans that include the review workflow (Growth and above). The export only covers languages and namespaces the downloading user is authorized to read.
Q. Do I need the regular review workflow for every language?
A. No. The Review AI workflow routes low-confidence AI translations into review selectively, across all languages. Enable the regular review workflow for the languages where everything should be reviewed, and let confidence-based routing cover the rest.
Q. Is the export generated on Locize servers?
A. It is assembled in your browser from the project data your user is authorized to read, and downloaded directly. Nothing is published or stored elsewhere.
If you want your translation workflow on this footing before August 2, 2026: create a free Locize account, enable the review workflow and Quality Estimation for your languages.