What the AI Act Code of Practice V2 Means for the Picture Industry — CEPIC's Analysis Within Provenance For Trust
On 5 March 2026, the European Commission published the second draft of its Code of Practice on marking and labelling AI-generated content — the key instrument for implementing Article 50 of the AI Act. CEPIC, a member of the Provenance For Trust collective, is actively studying its implications. Here is what organisations in the visual content industry need to understand.
The publication of the second draft of the Code of Practice on 5 March 2026 marks a significant step in the implementation of the EU AI Act. This is not an abstract regulatory development for the visual content industry — it is a direct and practical obligation that will reshape how images, videos and other visual assets are produced, distributed and verified across Europe.
CEPIC, as the European federation representing the picture industry and a founding member of the Provenance For Trust collective, is analysing the draft's implications in depth. The question at the centre of this work is both legal and operational: what do these new marking and labelling requirements mean for the organisations, agencies and professionals who create, license and distribute visual content every day?
The Code of Practice is voluntary in nature — but the obligations of Article 50 that it supports are not. From 2 August 2026, the transparency rules become enforceable. The Code is the map. The deadline is fixed.
What the Second Draft Actually Changes
- Revised two-layer approach: secured metadata + watermarking
- Optional fingerprinting and logging
- Detection and verification protocols
- Greater flexibility and consolidation vs. V1
- Technically feasible and proportionate measures
- Design and placement rules for icons, labels and disclaimers
- AI-generated vs. AI-assisted taxonomy removed — simplified
- Task force to develop a future uniform EU icon
- Specific rules for artistic, satirical and editorial works
- Illustrative EU icon examples now in the annex
Feedback deadline: 30 March 2026 · Final Code expected: June 2026 · Article 50 enforceable: 2 August 2026
What This Means for the Visual Content Industry
For image agencies, picture libraries, photographers and visual content distributors, the second draft of the Code of Practice introduces both clarity and complexity.
The revised two-layer marking approach — combining secured metadata with watermarking — is technically more workable than earlier proposals. The removal of the AI-generated versus AI-assisted taxonomy reduces one source of ambiguity that had generated significant concern in the content industry. And the provisions for artistic, creative and editorial works acknowledge that not all content operates under the same conditions of production and distribution.
But the fundamental question remains: how do organisations that manage millions of assets — some AI-generated, some human-made, many combining both — implement a marking and verification infrastructure before August 2026 at a cost and complexity that is genuinely proportionate?
This is the question CEPIC is bringing to the analysis of the draft within Provenance For Trust. It is not a question of whether to comply — it is a question of how compliance can be made workable, effective and fair across an industry of very different actors and scales.
- Analysing the legal and operational implications of the Code of Practice V2 for the picture and visual content industry
- Representing the interests of image agencies, picture libraries and visual content professionals in the compliance process
- Contributing sector-specific expertise to the Provenance For Trust collective's response to the Commission's marking and labelling framework
- Providing feedback on the draft Code ahead of the 30 March 2026 deadline, as part of the collective's broader engagement with the AI Act implementation process
Provenance For Trust: Building the Answer Together
The publication of the Code of Practice V2 is a reminder that the transparency obligations of the AI Act are no longer a future concern. They are an immediate operational reality.
Provenance For Trust was built on the conviction that no single actor — however capable — can solve the content authenticity challenge alone. The picture industry, the press, journalism institutions, technology providers and civil society organisations each bring a perspective that is necessary to build a framework that is technically rigorous, legally sound and practically workable.
CEPIC's presence inside Provenance For Trust is not incidental. It reflects the reality that the AI Act's transparency obligations will be felt most directly by the industries that produce, distribute and license visual content at scale — and that those industries must have a voice in shaping how compliance is implemented.
The work continues. The deadline is clear. And the collective is ready.
Your organisation, sector or institution has a stake in how AI content transparency is implemented in Europe. Join Provenance For Trust and help shape the answer.
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