Require context-specific viewer disclosure: What should the buyer require?
Watermarking alone is insufficient; the buyer must address the actual interaction and synthetic-content context.
The question
Assume EU AI Act transparency duties apply to software procurement. A vendor supplies a tool that generates synthetic product demonstrations and claims its embedded watermark satisfies every transparency duty. Procurement records do not show whether viewers interact directly with the system or could mistake demonstrations for real footage. What should the buyer require?
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- Require context-specific viewer disclosure with implementation evidence. ✓The buyer should establish the relevant interaction and synthetic-content context and obtain evidence that appropriate disclosure reaches affected viewers.
- Inspect generated files on a quarterly schedule.Sampling may detect defects, but it does not provide the context-specific disclosure required for users or viewers.
- Assign every statutory transparency responsibility to the vendor by contract and rely on its watermark.A contract may allocate tasks, but it cannot override statutory duties or show that watermarking fits the actual disclosure context.
- Test watermark durability.Durability may support a labeling control but does not establish which viewer-facing disclosure duties apply.
The trap
Ask who encounters the content, how it is presented, and whether the proposed disclosure fits that context. How to remember it
Watermarking alone is insufficient; the buyer must address the actual interaction and synthetic-content context.
How many of these would you get right?
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