Disclosed. Labelled. Traceable.
Article 50 of the EU AI Act requires AI transparency in interactions and content. CLEAR is the governance framework that turns those obligations into an operational system — so AI interactions are disclosed, AI-generated content is labelled, and both become traceable and evidenced across your organisation, consistently rather than case by case.
Article 50 of the EU AI Act · in force 2 August 2026.
The problem
AI is scaling faster than the systems meant to keep it transparent.
AI is now deeply embedded in how organisations communicate, create content and make decisions. The obligation to be transparent about it has become reality. Most organisations can confirm that they use AI applications, but cannot show where exactly it is used in their content, label it consistently, or make its use traceable on request.
AI is now embedded in
- — Communication and marketing systems
- — Content production pipelines
- — Decision and approval workflows
- — Customer-facing conversational interfaces
But transparency stays fragmented
- — Labelling, without understanding the system behind it
- — Compliance, without visibility into the architecture
- — Governance, without traceability
- — Documentation that can't reconstruct what happened
You can see that AI is being used. What usually can't be traced is which content it generated, whether that was disclosed, and where accountability sits. That is exactly the gap regulators, supervisory bodies or courts will confront you with.
Why now
Media isn't a seamless value-chain. It's an unsynchronised system.
With the EU AI Act's transparency obligations now in force, organisations must not only know the rules but implement them and operate in compliance. The implementation problem is structural. The media value chain consists of many different actors: model developers, AI system providers, AI system deployers, distributors and audiences. In many instances, content is modified with and without AI applications, without traceability or documentation.
In force
2 Aug 2026
Labelling & visual transparency
Penalty
€15M / 3%
Maximum exposure
In force
2 Dec 2026
Embedded & technical transparency
Many participants, a heterogeneous ecosystem, no content provenance. When regulation asks who created something, with what, and whether it was disclosed, the value chain often cannot answer. That is exactly the gap CLEAR exists to close — by anchoring transparency systemically instead of leaving it to individual improvisation.
The reference document
The CLEAR Whitepaper
Why thinking about transparency only at the output stage stops working once AI sits inside your systems — and how CLEAR maps the EU AI Act obligations to the architecture that has to evidence it.
Transparency
by Design
A CLEAR framework for AI transparency under the EU AI Act, Article 50.
The framework
Five dimensions of AI transparency.
CLEAR isn't a checklist — it's a model for systematically designing transparency into the system. The framework defines the operationalization; the instruments guide implementation into practice.
Conversational Transparency
Interaction transparency. People are informed that they are interacting with an AI system — throughout the whole interaction, not just at the first screen.
Labelling
Media transparency. AI-generated and AI-edited content is visually labelled as required by the EU AI Act. Implementation is standardised across images, video, audio and text.
Embedded Watermarking
Synthetic content is marked technically and machine-readably. This is embedded into the workflow and architecture — by design, not after the fact.
Accountability
Clear responsibilities across the supply chain and for internal teams and processes are defined and agreed.
Regulatory Readiness
The wider applicable regulatory requirements (e.g. GDPR, copyright) are accounted for — including evidence on request.
CLEAR is not a checklist. It is the systematic implementation of Transparency by Design.
The CLEAR Score
How transparent is your AI approach, really?
Ten questions across the five CLEAR dimensions. You'll get a maturity assessment, a breakdown by dimension and a gap assessment. For orientation.
Your CLEAR Transparency Report
AI transparency maturity, generated from your responses across the five CLEAR dimensions.
Move from assessment to implementation
Used by organisations preparing for AI governance and transparency obligations in Europe.
Email me a copy of this report
For orientation, based on your responses.
Implementation
Put CLEAR into practice —
with the working artefacts.
The CLEAR working artefacts assist you in turning the framework into the transparency and governance standards your team runs day to day. We can share our standard best practices or customize together.
AI labelling guideline
AI content labelling icons
Governance structure template
Accountability mapping
Regulatory readiness review
Advisory
We design and implement the system with you.
Led by Jeannette Gorzala — who helped shape the AI Act and now advises on how it is applied — CLEAR Advisory takes you from assessment to a transparency system that holds up.
Services
- — Governance design
- — System & transparency audits
- — EU AI Act readiness
- — Transparency architecture
Formats
- — Executive & board advisory
- — Workshops
- — Implementation programmes
- — Ongoing oversight support
Start with CLEAR
Know where you stand. Then build the system.
Tell us what you're working on and we'll come back to you. Or calculate your CLEAR Score first to see where you stand.
Take the CLEAR Score →Thanks — we'll be in touch ✓
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