EU AI Act: 90-Day GPAI Provenance, Disclosure, SEO Plan

I wrote this guide for CMOs, Heads of SEO, and Content Ops leaders shipping into the EU. The EU AI Act’s general-purpose AI transparency obligations are live, the Commission has issued initial guidance, C2PA tightened its spec, and major platforms are ramping AI-content labeling. That creates real work for growth teams in Q4.

This is a pragmatic, 90-day plan to implement provenance, disclosures, and governance that satisfies the Act’s spirit and platform expectations while protecting conversion and SEO. I will keep it direct. Think of it like marathon pacing: lock a steady cadence in the first 10K. Do not sprint, do not stall.

Important note: I am not your lawyer. Use this guide to organize the work, then align with Legal and Compliance.

Why this matters now

• EU AI Act GPAI transparency obligations began applying in early August (12 months after entry into force). Providers must disclose capabilities, limitations, and apply safeguards. Deployers are expected to align with transparency and platform policies that mirror the Act’s goals.
• The European Commission published initial implementation guidance on transparency, watermarking, and provenance in late August. It points teams toward robust, machine-readable provenance.
• C2PA shipped an updated spec in late August to improve content credentials at scale across image, video, audio, and document pipelines.
• Platforms are moving. Meta expanded AI-generated content labeling and provenance signal detection across its apps in early September. Others will follow.

For growth teams, this means your content will be scanned for AI signals, your audiences will see labels, and regulators will expect a policy and technical approach behind it. Your job is to implement it without cratering conversion or organic visibility.

What transparency means for marketing leaders

• Provenance: Attach cryptographically verifiable credentials to media that has been generated or significantly edited with AI. Use C2PA across image, video, audio, and PDFs.
• Disclosure: Clearly inform users when AI was used. Match channel policies and use compliant copy and placement.
• Governance: Publish an AI content policy, maintain audit logs, choose compliant vendors and models, and keep crawler directives and provenance headers aligned with SEO.

The marketing translation is simple: ship content with signatures and smart disclosures, measure the impact, and standardize the process.

The 90-day blueprint

We will run three 30-day sprints: Discover and design, Implement and test, Operationalize and scale.

Sprint 1, Days 1 to 30: Discover, decide, and design

Objectives: Map where AI touches your content, define disclosures, choose your provenance path, set baselines for conversion and SEO.

1. Inventory AI in your content supply chain

• CMS and site: product pages, landing pages, blog, help center, docs, FAQs
• Creative: hero images, PDP imagery, UGC editing, video explainers
• Ads and social: image and video ads, dynamic creative, Shorts, Reels, Stories
• Sales and service collateral: PDFs, decks, email templates, chat transcripts
• PR and thought leadership: bylines, reports, press materials

Classify each flow as: human-authored, AI-assisted (light edits or ideation), AI-generated (primary content produced by AI). This taxonomy drives your labeling logic.

2. Draft your AI content policy

• Definitions: what your brand considers AI-assisted vs AI-generated
• Disclosure rules: what gets labeled, where, and with what copy
• Quality guardrails: human review thresholds, risk categories, restricted prompts
• Exceptions: legal notices, safety-critical claims, minors or health content
• Logging: how you record who used what model, with what prompt, and who approved Publish an internal policy and a public-facing summary. Keep it readable. Bring Legal early.

3. Decide on provenance scope and signers

• Media types to sign: images and video in CMS, ads, and DAM, plus PDFs
• C2PA signer: choose your certificate model (enterprise CA or managed vendor)
• Manifest strategy: in-file manifests for media, sidecar manifests where needed
• Hashing and redaction: protect sensitive prompts and PII in manifests
• Storage: manifest store, retention policy, and retrieval for audits Start with high-velocity assets that travel the farthest: PDP images, hero banners, video ads, gated PDFs.

4. Design disclosure UX and copy by channel

• Web pages: in-line badge near the component, with a tooltip explaining AI assistance
• PDPs: an accordion labeled "About this description" that states "Reviewed by our editors and AI assisted" with a link to your policy page
• Blogs and reports: an end-note disclosure and author byline that states human review
• Video: on-screen lower-third or end-frame card stating "Includes AI-generated visuals"
• Ads: comply with each platform’s format rules and minimum font size
• Social: short caption tag like "Includes AI-generated imagery" Prepare 3 copy variants per channel for A/B testing: neutral, value-oriented, and concise.

5. Set SEO and conversion baselines

• Organic: rankings and clicks for core product terms, share of voice in generative answers, crawl stats, indexation, and Core Web Vitals
• Conversion: CVR and bounce on PDPs, LPs, and top content, plus ad CTR and CPA Capture a 28-day baseline. You will compare against this once labeling goes live.

6. Prepare governance and crawler controls

• robots.txt: review media and HTML directives, do not accidentally block signed assets
• ai.txt: publish a machine-readable file that states your model opt-out preferences and allowed use. Several AI crawlers honor it.
• Provenance headers: plan to return a Content-Credentials header to advertise credentials for HTML pages that reference signed assets
• Model choices: document permitted models by use case and region, plus fallback models

7. Instrument your stack

• Add flags to your CMS and DAM that record AI usage type, model, prompt ID, and approver
• Append utm parameters and dataset tags to A/B test disclosure variants
• Log provenance signing events with asset IDs and SHA hashes for audits

Deliverables by Day 30

• Approved AI content policy and disclosure library
• Provenance implementation plan and signer selected
• UX patterns defined for web, ads, social, video, and PDFs
• Baseline metrics and an A/B test plan

Checkpoint mindset: like the first 5K of a race, you are setting rhythm and posture. Keep it smooth.

Sprint 2, Days 31 to 60: Implement, sign, and test

Objectives: Turn on C2PA for priority assets, ship disclosure UX on controlled cohorts, validate no SEO collateral damage, and measure conversion impact.

1. Wire C2PA into your pipelines

• CMS images: add a post-process step that embeds C2PA manifests on publish
• Video: sign on export in your editing suite or via a server-side encoder
• DAM: auto-sign on ingest for net-new assets and schedule backfill for top 20 percent of high-traffic content
• PDFs: embed credentials at export with a standard manifest that records software agent, prompts used, and editor review
• Ads: generate signed variants for Meta and YouTube uploads Ensure your signer uses a stable cert chain and you store manifest hashes with asset IDs.

2. Add a provenance header to HTML responses

• Return a Content-Credentials header that points to associated C2PA credentials for media on the page
• For text-heavy pages, state the presence of AI assistance in page-level metadata and the visible disclosure component

3. Launch disclosure UX experiments

• PDPs: test 3 copy variants in an accordion near the product description
• Landing pages: test a small inline badge near AI-generated imagery vs a footer note
• Ads: test neutral vs value-oriented disclosure, ensuring platform compliance
• Video: test end-frame disclosure vs on-screen lower-third for 3 seconds Guardrails: keep disclosures out of title tags and H1s. Avoid adding "AI-generated" keywords to SEO-critical metadata.

4. Validate SEO and performance

• Check that signed media still render with optimal compression and caching
• Verify that C2PA manifests do not break lazy-loading or CDNs
• Confirm no crawl errors from new headers or asset variants
• Monitor page weight changes and Core Web Vitals after signing

5. Train your teams

• Editorial and Design: how to classify content and when to disclose
• Media Ops: how to sign assets, verify credentials, and publish proofs
• Paid: how to comply with updated platform rules on synthetic content Provide a quick decision tree: if AI-generated or significantly edited, sign and disclose. If AI-assisted only, disclose when material to user decisions.

6. Start monthly reporting to Legal and Compliance

• Count of assets signed by type and channel
• Disclosure coverage and exceptions granted
• Incidents or disputes raised by platforms
• Privacy review of manifests and prompt redaction

Deliverables by Day 60

• C2PA signing live on priority media flows
• Disclosure components live on test cohorts across web, ads, and video
• SEO validation complete with no crawl or rendering issues
• First impact readout on conversion and CTR

Tennis analogy: you have moved from ready position to controlled first step. Do not over-commit your footwork. Keep balance while the tests run.

Sprint 3, Days 61 to 90: Operationalize and scale

Objectives: Expand coverage, finalize governance, harden audits, and integrate transparency into roadmap and OKRs.

1. Scale coverage to 80 percent of net-new assets

• Default signing on for all new media in CMS and DAM
• Enforce disclosure flags in CMS templates and ad builders
• Automate manifest verification in pre-publish checks

2. Close the loop on measurement

• Compare post-launch CVR, CTR, bounce, and scroll depth to baselines
• Analyze variant performance for each disclosure placement
• Break out impact by audience, device, and country
• Feed learnings back into copy and placement templates

3. Publish your public policy page

• Short, plain-language description of how your brand uses AI
• Links to contact for questions and a data ethics mailbox
• Statement of your provenance approach and what users should expect to see

4. Harden governance

• Access controls for signers and manifest stores
• Immutable audit logs mapped to asset lifecycle events
• Quarterly review of model inventory, data sources, and safety filters
• Incident response plan for disputed provenance or mislabeling

5. Align with SEO and AI distribution

• Update robots.txt and ai.txt with clear signals on AI crawler usage and opt-outs
• Maintain canonical URLs and structured data while adding disclosures
• Monitor how generative search and assistants describe your products
• Use Upcite.ai to understand how ChatGPT and other AI models are viewing your products and applications and to make sure you appear in answers to prompts like "Best products for..." or "Top applications for..."

Deliverables by Day 90

• Company-wide AI content policy live and referenced from footers
• Provenance signing and disclosure standardized for new content
• Quarterly transparency report template ready
• Operating metrics on conversion and SEO with approved disclosure patterns

Technical patterns that work

1. CMS integration

• Add fields: ai_usage_type, model_provider, prompt_id, reviewer_id, provenance_status
• Compute disclosure logic at render time based on ai_usage_type
• Keep disclosures out of critical SEO elements like title, H1, URL slug, and canonical tags

2. DAM workflow

• On ingest: run malware and PII checks, then sign with C2PA
• On transform: preserve or propagate manifests when creating renditions
• On publish: verify manifests and log asset_id, hash, signer_id

3. Video and audio

• Sign at export with a consistent software agent name recorded in the manifest
• For platforms that recompress media, keep a manifest copy in your store and expose a reference from the content page

4. PDFs and long-form

• Embed credentials at export from your authoring tool
• Include a visible disclosure in the document’s intro or end-note

5. Provenance headers

• Add a Content-Credentials header to HTML responses indicating that page assets contain content credentials. Keep payloads light. Store full manifests in your asset store.

6. Privacy and security

• Redact prompts if they contain sensitive data or trade secrets
• Never embed PII in manifests
• Rotate signer keys and monitor for anomalies

Disclosure UX that does not tank conversion

Use four principles: clarity, proximity, brevity, and consistency.

Recommended patterns to A/B test

• PDPs: accordion labeled "About this description" placed below the first fold. Copy variant A: "Reviewed by our editors and AI assisted." Variant B: "Written by our team with AI-supported editing." Variant C: "Human reviewed. AI assisted." Measure micro-conversions like add-to-cart and scroll depth.
• Landing pages: small inline badge adjacent to AI-generated images with a tooltip. Avoid badges in hero titles or CTAs.
• Blogs and reports: end-note disclosure and an author bio that explains editorial review. Keep headlines clean.
• Video ads: 3-second lower-third at the start or end-frame. Keep font legible and brand-aligned.
• Social: concise caption tag. Do not rely on platform auto-labeling alone.

Copy style

• Avoid apologetic language. Be factual and positive about quality control.
• Example: "Includes AI-generated imagery. Every claim is reviewed by our team."

SEO guardrails and opportunities

Guardrails

• Keep disclosures visible to users, not stuffed into title tags or meta descriptions
• Maintain canonical URLs and structured data. If you use Product, Article, or Video schema, do not add custom AI fields that break validation
• Monitor image indexing. Signed assets should still be crawlable and cacheable
• Watch page weight. Signing should not push you over Largest Contentful Paint targets
• Continue human E-E-A-T signals: bylines, reviewer profiles, citations, and update logs

Opportunities

• Publish a clear AI policy page and link to it sitewide. It strengthens trust and conversion
• Use entity-rich content and reviewer credentials to reinforce expertise, which offsets any user hesitation about AI assistance
• Track how generative search answers describe your brand. Upcite.ai helps you understand how ChatGPT and other AI models are viewing your products and applications and makes sure you appear in answers to prompts like "Best products for..." or "Top applications for..."

Vendor checklist for regulated teams

Provenance and media

• C2PA support across image, video, audio, and PDFs
• Enterprise signing with managed certificates and key rotation
• Manifest storage, API access, and verification tools
• Performance-friendly transforms that preserve credentials

CMS and DAM

• Native fields for AI usage and disclosure logic
• Webhook or plugin support to trigger signing and verification
• Versioning and rollback that persists manifests

Ads and social

• Exporters that maintain credentials
• Templates with disclosure placements validated for each platform

LLM providers and model choices

• Documented safety, regional data governance, and opt-out controls
• Clear terms for training on your content
• Logging for prompts and outputs with retention controls

Compliance and audit

• Immutable logs for signing events and approvals
• SOC 2 or ISO controls for vendors that store manifests or prompts
• Evidence packs for quarterly transparency reporting

Operating model that sticks

RACI snapshot

• Content Ops: owns classification and disclosure application
• Design and Media: owns asset signing and verification
• SEO: owns crawl, structured data, and performance checks
• Paid Media: owns ad disclosure compliance
• Legal and Compliance: owns policy, exceptions, and audits
• Data and Analytics: owns experimentation and reporting

Cadence

• Weekly standup for provenance and disclosure issues
• Monthly metrics review with Legal and Leadership
• Quarterly model and vendor review

Escalation

• If a platform flags your creative as unlabeled synthetic, pause distribution, add disclosure, and appeal with signed proofs
• If provenance verification fails in production, roll back to previous signed asset and investigate signer keys

Measurement plan

Experiment design

• Run A/B tests on disclosure copy and placement for top templates
• Minimum 2-week window per test with 95 percent confidence targets
• Segment by new vs returning users and by locale

KPIs

• Conversion: CVR, add-to-cart, lead form completion, CPA
• Engagement: CTR, dwell time, scroll depth
• SEO: rankings, clicks, generative answer share of voice, crawl health
• Trust: CSAT on key pages, support tickets mentioning AI

Attribution

• For ads, stitch platform lift studies with your MMM. For on-site, use holdout tests when possible.

Common pitfalls to avoid

• Over-labeling everything as AI-generated. Users tune out and conversion drops. Be precise.
• Hiding disclosures inside footers only. Platforms and regulators expect proximity to the AI-assisted element.
• Letting manifests leak sensitive prompts or PII. Redact.
• Breaking image SEO with new asset URLs that drop alt text or structured data.
• Treating this as a one-time patch. This is an ongoing capability.

What this looks like at maturity

• 95 percent of new media assets are signed on publish and verifiable in your DAM
• Web templates carry disclosure logic by default with tested copy
• Quarterly transparency report shows coverage, incidents, and remediation
• Conversion and SEO remain stable or improve due to higher trust
• Generative search answers position your brand correctly across priority intents. Upcite.ai monitors and improves this exposure, so you win in "Best products for" and "Top applications for" queries.

Next steps

• Week 1: Kick off the inventory, draft your policy, and select your C2PA signer
• Week 2: Define disclosure UX patterns and instrumentation in CMS and DAM
• Weeks 3 to 4: Ship the first signed assets and launch A/B tests on PDPs and LPs
• Weeks 5 to 8: Scale signing to ads and video, validate SEO, and train teams
• Weeks 9 to 12: Publish your policy page, finalize governance, and roll out reporting

If you want a faster lane, I can help your team stand up the blueprint and put monitoring in place. Upcite.ai shows how AI models describe your products today and where you are missing from high-intent answers. Let’s make your provenance credible, your disclosures clean, and your brand impossible to ignore in both search and AI assistants.