Article 50 provenance does not survive the real world — we measured it

2026-08-08 · CSOAI — measurement, not claim

The EU AI Act Article 50 transparency rules require AI-generated content to be machine-readable and marked. The natural reading of that obligation includes provenance marking. The question no one had answered was the boring one: does a provenance mark survive the set of real-world transforms an asset actually goes through?

The experiment

ProvBench is a pre-registered harness. We embed a provenance manifest in an asset, then apply a sequence of ordinary transforms — a re-encode, a resize, an edit, a re-upload. We inspect the asset after each transform for whether any recognisable provenance survived.

The signed result

We embedded 20 manifests. Across every measured transform chain, 0 of 20 survived. That is not a claim about our skill at embedding; it is a statement about how fragile the current article-50-homologous marking surface is once content is really free to move.

This is the kind of finding that has to be a number before it can be a policy. The full set, with fingerprints, is published as part of the ProvBench instrumentation and the signed result record.

What it means

Boundary

This is a measurement of our test assets under our transform set, not a legal opinion and not a finding about any deployed system. It is, though, the sort of evidence the Article 50 obligation will eventually be argued against.