Who signs, and who answers
Who signs the statement that content is AI-generated, and who answers when the system gets it wrong. The law sets the goal, not the mechanism.
The question
Who signs the statement that content is AI-generated, and who answers when the system gets it wrong?
Why it is a decision and not a compliance item
Because the corpus says it in one line: “items 4, 5 and 7 are product decisions dressed up as compliance items”. The law sets the goal, not the mechanism.
On age verification, law 132/2025 art. 4 para. 4 does not prescribe the mechanism. So you choose the mechanism — and if you do not choose it you choose it anyway, in the most defensive version available.
On liability in case of error the corpus records only that it is “to be defined”. No source says who answers, and this card does not invent it: it says the box is empty and that somebody will have to fill it.
What the literature says
- Eight obligations with fixed dates, three of which leave design latitude: item 4 (minors), item 5 (agentic actions), item 7 (Google toggle).
- The disclosure has to be accessible: it is not enough for it to be there, it has to be perceivable — announced by screen readers, with sufficient contrast, not disappearing after a few seconds. It is a design requirement, not a legal-text one.
- The accessibility of the statement intersects with the European Accessibility Act, in force since 28 June 2025, and therefore with the problem that no commercial tools exist to verify it on generative content.
The cost of either branch
Owning the mechanism costs product time on non-negotiable constraints, with a date that does not move.
Not owning it costs you the mechanism: maximally restrictive age verification, confirmation reduced to a pop-up, disclosure that is compliant and invisible. In both cases you are compliant. In one case the experience is designed, in the other it is not.
How it is measured
Compliance is binary and can be verified. The mechanism is not: there is no published measure of the conversion cost of a tighter or looser age check. It has to be decided without that figure, and it is better to know so in advance.
Who decides
Legal / Compliance for the obligation, Product Manager for the mechanism. This card exists above all to make the cut line explicit, because it is the line nobody draws today: the obligation says what to achieve, the mechanism is product.
By when
Four dates in eighteen months:
| Date | Obligation | Status |
|---|---|---|
| 28 June 2025 | European Accessibility Act, EN 301 549 → WCAG 2.1 AA | in force |
| 17 June 2026 | Google toggle to opt out of AI answers | active, default value already in place |
| 2 August 2026 | AI Act art. 50 disclosure | in force |
| 2 December 2026 | Machine-readable marking of generated content | upcoming |
Three of the four have already passed. The only one still ahead is the marking of content already in production.
Where it falls
The regulatory perimeter is the parent decision. Then The user expects the system to act, Accessibility and hybrid interfaces, Empathy and social presence.