Frontier · Deploy

Article 50 is in force. Your campaign imagery is in scope.

EU AI Act, content provenance and DPP-ready product data - as an architecture problem, not a policy document.

AI governance and provenance for fashion covers three obligations: EU AI Act transparency for AI-generated content and public-facing AI interfaces, cryptographic provenance on generated assets, and structured product data prepared for Digital Product Passport requirements under ESPR.

The problem

Article 50 transparency obligations and the GPAI penalty regime took effect on 2 August 2026. Most brands running AI campaign imagery in the EU do not know they are in scope.

What we install

Not advice. Working parts.

  1. 01AI system inventory and role classification, provider against deployer
  2. 02Article 50 disclosure implementation
  3. 03C2PA provenance on generated assets
  4. 04Model and prompt documentation
  5. 05DPP data spine ahead of the textile delegated act
  6. 06Incident reporting workflow across NIS2, GDPR and AI Act timeframes
What you get

Artifacts, not a deck.

AI system inventory with role classification

Disclosure and provenance applied at generation

Model and prompt documentation set

DPP-ready product data spine

On the platform

Consulting installs it. The platform runs it.

This capability has a counterpart on McLeuker AI, the agentic platform the same team built and operates. The engagement is how it arrives inside your operation, loaded with your brand context; the platform is where it runs afterwards.

How the engagement runs

Deploy. Thirty days onto McLeuker AI, then retained.

Your operation loaded onto agents that already know the fashion domain.

01Week 1

Diagnose

Where agents change the economics, and where they do not.

02Week 2

Design

Which agents, which tools, which data, which guardrails.

03Week 3

Deploy

Shipped into the operation with your context loaded.

04Week 4

Operate

Retained partnership, monthly sessions, continuous updates.

Signed byGeneral CounselChief Compliance OfficerChief Sustainability Officer
Questions

What buyers ask first.

Are we a provider or a deployer under the AI Act?

Most fashion brands are deployers, but publishing a public-facing AI interface or materially modifying a model can change that. Role classification is the first step of the install because every other obligation follows from it.

Does Article 50 really cover campaign imagery?

Transparency obligations cover AI-generated content published to the public, which includes campaign and lookbook imagery. They have been in force since 2 August 2026.

Should we wait for the textile delegated act before doing DPP work?

The delegated act is expected in 2027 with a transition of at least eighteen months, so compliance realistically lands in 2028-29. The data spine is the slow part and is worth starting now; the schema binding can wait for the text.

Is this an ESG or a sustainability engagement?

No. It is a data architecture engagement. The reporting output is downstream of whether your product data is structured, provenanced and retrievable, and that is an engineering problem.

Start with the diagnostic.

Four weeks, fixed fee, and a ranked map of what is worth automating in your operation - including what is not.