SDK 0.7.2a1 · source review 2026-11-10.
Short fragments below locate the main requirements. The complete provision, role, exceptions and operative dates govern; these fragments are not a substitute. Technical mapping and engineering policy are identified separately.
| Source | Short original fragment | Implementation relevance |
|---|---|---|
| EU 50(2) | “marked in a machine-readable format” | Export a software-readable indication, not just a marketing notice |
| EU 50(2) | “effective, interoperable, robust and reliable” | Evaluate the combined marking/detection route |
| EU 50(2) | “as far as this is technically feasible” | Record limitations, cost and state-of-art reasoning |
| EU 111(4) | “by 2 December 2026” | Specific transition for pre-2-August provider systems |
| California 22757.2 | “at no cost to the user” | Operate the relevant verification access |
| California 22757.2 | “strictly necessary to comply with this chapter” | Minimize tool/user-content personal-data processing |
| California 22757.3 | “permanent or extraordinarily difficult to remove or tamper with” | Removal resistance is a separate evidence question |
| Voluntary Code 1.1.1 | “digitally signed and time-stamped” | Signed metadata/time and key operations within the Code route |
| Voluntary Code 2.1.2 | “including at least a hash” | Downloadable signed detection report includes asset association |
| Voluntary Code 3.4(c) | “by 2 February 2027” | Route-specific watermark-detection interoperability milestone |
| Guidelines §4.2, paragraph 70 | “without the means for their detection being available” | A mark alone is not a complete marking/detection solution |
Authority and version
The EU Act and California Code are binding law. The Commission Guidelines explain implementation; they are not an amendment of Article 50. The voluntary Code is a recognised practical framework, not identical to the statute or a product certificate. C2PA is a technical standard; TrustMark and the three video modes are implementation choices. A trusted TSA on every production export and a +5-minute issuance allowance are SDK policies, not statutory frame/time thresholds.
For Guidelines, keep distinct the page's initial publication date (20 July 2026), its update (5 November 2026), and the inspected PDF's edition (Brussels, 5 November 2026, C(2026) 7702 final). The current Code PDF was inspected by measure number; no edition date is inferred from a filename.
Source review record records URLs, retrieval methods, PDF fingerprints and scope. Official source material retains its own reuse terms. Public docs contain short attributed fragments and links; full downloaded source files are retained in the maintainer audit evidence, not re-licensed as Ariadne documentation.