Ready for the transparency rules in an afternoon

Why prompt archives prove almost nothing

The AI Act's documentation and logging duties apply to high-risk systems, not image generation, and machine-readable provenance is the tool provider's job. The law judges the published final image, never the process behind it.

If the image depicts a recognisable real person it does not matter that no name appeared in any prompt. Conversely, a prompt containing a celebrity's name is no violation if the final image does not resemble the person. Archiving a thousand prompts therefore proves almost nothing. An image can also be the result of generations, inpainting, upscaling and retouching across several tools.

What is actually needed is evidence about the outcome and responsibility in the contract — and that is entirely doable.

Six items that hold up

• Likeness check of the finished cast. One documented check per locked character, not per generation. It is the final image's identifiability that is the legal test, so it is what must be checked and attested.
• The reference set. The character's canonical images stored in the world bible, with a lock date. That is the cast's certificate of origin, not the prompt history.
• Tool list with terms. Which tools are in the pipeline and that their licences allow commercial use, ideally with indemnity. One list per pipeline, not per image.
• Intact file provenance. The C2PA metadata in the delivered file carries the provenance automatically, including the tool chain. The file documents itself; no manual logging is needed.
• Written warranty from the agency. A delivery attestation that no real referents have been used without agreement and that no known third-party material is included. For a buyer this is the single most important item, because you cannot audit the agency's internal process anyway. The warranty puts responsibility where it belongs.
• Prompt policy instead of prompt archive. A rule that real names and the styles of living authors are not written into prompts, with spot checks. A prompt saying "in the style of X" can be used against you as evidence of intent, so the policy is worth more than the archive.

What a good partner delivers

For us, compliance is a side effect of how we produce. Locked characters with likeness attestations, a world bible with canonical reference images and lock dates, files where C2PA provenance stays intact, a tool list with licence terms and a written warranty on every delivery.

Ask your partner to show the equivalent, whoever they are. If they cannot, the rules are not the problem.