The Proposed Solution

A technical standard coupled with a legal obligation

Obligations for AI generators

  • Apply a standardised visual symbol to all AI-generated content
  • Embed signed provenance metadata (C2PA-type standard)
  • Timestamp and cryptographic signature of content at the source
  • Identification of the tool or model that generated the content

Obligations for platforms

  • Display the AI marker visibly in the user interface
  • Preserve provenance metadata without alteration or deletion
  • Provide a public provenance verification API
  • Reject or re-label re-uploads of AI content without a marker

Obligations for creators and publishers

  • Not to remove or alter provenance markers and metadata from AI-generated content
  • Not to distribute AI-generated content by presenting it explicitly or implicitly as authentic
  • Not to republish content whose marker has been deliberately removed
  • Aggravated liability in electoral, financial contexts or identity theft cases

Sanctions

In cases of deliberately deceptive distribution of unlabelled AI content: significant financial penalties for non-compliant platforms and generation tools, criminal liability for malicious users.

C2PA Standard

Technical foundation: an open and sovereign standard

AI content traceability relies on cryptographically signed metadata embedded in the file at the source. Several initiatives already exist, including the Coalition for Content Provenance and Authenticity (C2PA), voluntarily adopted by Adobe, Microsoft and Google. But a European legal obligation cannot rely exclusively on a standard governed by private actors.

  • Open and auditable — public source code, complete documentation, no proprietary lock-in
  • Democratically governed — under the aegis of a public body or independent multi-stakeholder instance (W3C, ISO, or dedicated European body)
  • Interoperable — compatible with existing implementations like C2PA, without exclusively depending on them
  • Sovereign — the definition of the standard must not belong to companies with direct commercial interests in its application

C2PA can serve as a working basis and inspiration. It cannot be the definitive answer.

Already adopted by: Adobe Microsoft Google Sony Nikon Canon
This proposal does not restrict AI creation. It simply requires transparency about the origin of content.
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