As part of the Provenance R&D programme, funded by the Ministry of Culture (DGMIC), CEPIC was commissioned to carry out a regulatory compliance study to determine the extent to which the Provenance For Trust platform can help media sector stakeholders meet relevant European obligations and recommendations regarding the detection, labelling, traceability and marking of content generated or manipulated by artificial intelligence.
The study focuses in particular on the transparency obligations set out in Article 50 of Regulation (EU) 2024/1689 on artificial intelligence (‘AI Act’). These may apply to certain media organisations when they use or publish content generated or manipulated by AI, including, where applicable, deepfakes.
The Provenance For Trust platform aims to provide the media with tools for verifying the origin, traceability and labelling of content provenance. In this context, it sits downstream of the value chain, not as a content generation tool, but as a mechanism designed to help the media verify the origin of content, ensure its traceability and document its provenance. To this end, it relies in particular on building blocks such as C2PA metadata, detection mechanisms, and labelling and signing tools, in order to offer the relevant stakeholders operational support in implementing certain transparency requirements.
The preliminary analysis highlights, however, that the challenge lies not only in the technical capacity to detect or trace content, but also in the ability to support legally sound assessments and to document their justification within editorial workflows. In this regard, the study proposes several courses of action to address this key issue.
The full study will be finalised following the publication of the expected instruments relating to the interpretation and implementation of Article 50 of the AI Act, in order to align the recommendations as closely as possible with the final version of the applicable framework.
According to Xavier Bruni, project lead for the Provenance For Trust project and co-funder of Trust My Content:
“With Provenance For Trust, the real challenge posed by Article 50, and in particular paragraph 4, lies not only in the principle of transparency, but in its implementation. Ensuring reliable, interoperable and large-scale traceability, without complicating usage or compromising confidentiality, is the true technological challenge. ”
Sylvie Fodor, executive director of CEPIC, comments:
“Provenance For Trust is designed to serve as a compliance support tool, strengthening the ability to provide evidence and helping certain media stakeholders implement the transparency requirements set forth in Article 50. This study also allows us to analyze a legal framework that is still under development and to better understand the challenges faced by technology developers seeking to meet the media’s expectations regarding transparency.”