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QENEX LTD · Lab

Article 50(2) marking — 2 December 2026

78 days remain for systems placed on the market before 2 August 2026. New systems have been bound since 2 August 2026. Official Commission FAQ: Transparency obligations under Article 50.

Check your output

Paste generated text or a media URL. Ten seconds. No account. Not a legal opinion. If the output is unmarked, checkout stays on this page.

The duty sits on the system, not the model

The Commission defines a provider as the person who develops an AI system, or has it developed, and places it on the EU market or puts it into service under their own name. Recital 97 is blunt: a model is not a system until you add components such as a user interface. If you wrap OpenAI, Anthropic, or an open-weight model and ship a chatbot, image, audio, video, or text product under your brand, you are the Article 50(2) provider. The model lab's SynthID or C2PA does not automatically travel through your wrapper.

Who this is for

A UK or EU SaaS that generates synthetic text or media for EU users and is not already covered by a watermark at a model they own. Typical: sales agents, support chat, image APIs, avatar video that is not already marked by Synthesia-class tooling, and any product whose output leaves the building unmarked.

Who this is not for

  • Personal, non-professional use.
  • Assistive standard editing that does not substantially alter the input.
  • Closed industrial loops whose output never reaches a person.
  • Anyone seeking a legal opinion or a substitute for counsel.
  • A play to lock out competitors. This is a marking API, sold to one buyer at a time.

What exists, and where Lab sits

  • Google SynthID and Adobe Content Credentials / C2PA — strong inside those vendors' generators. They do not mark a third-party wrapper by default.
  • IMATAG and similar forensic watermark vendors — enterprise, sales-led. Public Monitor plans start around €299 / month. Fine if you want a quote cycle.
  • Lab — self-serve. Check on this page, then £290 / month. Key after pay. Cancel through billing@qenex.ai. Not a Code of Practice certificate.

What you buy

  1. Run the check above on text or a media URL. Ten seconds. No account.
  2. If the output is unmarked, subscribe. Lab issues the API key after pay. Cards work wherever Stripe accepts them. Cancel through billing@qenex.ai.

The Commission and the AI Board assessed a voluntary Code of Practice as adequate for demonstrating Article 50(2), (4) and (5) compliance. The Code expects layered techniques where one method cannot meet effective, interoperable, robust, and reliable at once. Lab marking is a technical service for that duty. It is not a certificate that you have signed the Code.

Send this to your CTO

Subject: Article 50(2) marking — 2 December 2026. Body: We ship a generative system under our name. The Commission says the marking duty is on the system provider, including if we are outside the EU and the output is used there. New systems have been bound since 2 August 2026; systems already on the market have until 2 December 2026. Fine: up to €15 million or 3% worldwide turnover. Free check: qenex.dev/article-50. Checkout: £290 / month.

Why this SKU, not a new factory product

Walk-up buyers do not pay for “prompt-to-company.” They pay when a named duty, a date, and a fine sit on their desk. Dual-Rail Receipt is on /receipt. Lab checkout is on Pay. In-flight Pulse renewals stay on Pricing. The factory on this site stays a builder, not the first invoice.

Questions

Who has to mark AI-generated content?

Article 50(2) is a provider duty. Providers of AI systems that generate synthetic audio, image, video or text must ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated. Deployers have separate disclosure duties under Article 50(4).

We call OpenAI / Anthropic / Google. Are they the provider?

Usually not for your product. Article 50 applies to AI systems (an app or interface), not to the bare model. If you develop a system, or have it developed, and place it on the EU market or put it into service under your own name, you are the provider — even when the model is someone else's. That is the typical UK/EU SaaS wrapper.

What is the 2 December 2026 date?

Article 50 applied from 2 August 2026. A limited grace period covers only the Article 50(2) marking and detection duty, and only for AI systems placed on the market before 2 August 2026. Those systems must comply from 2 December 2026. Systems launched on or after 2 August 2026 are already bound.

Does this apply outside the EU?

Yes, if the output of the AI system is used in the EU. Establishment outside the Union does not remove the duty.

Is this a legal opinion?

No. The free check is a detectability test. The paid API is a marking service. QENEX LTD is not a law firm. Read the Commission FAQ and, if needed, instruct counsel.

Billing: billing@qenex.ai. Full catalog: Pricing. Fallback check: lab.qenex.ai.