# ORF-backed Austrian films must log AI use by timecode and drop AI music

Producers under the Film/Fernseh-Abkommen must deliver a cut list that separates AI, archive and their own footage.

Published 23 October 2026 by EuGFA in The Briefing. Interests: Policy.

## What happened

The Austrian Film Institute (ÖFI) has set out how the AI Act affects projects under the Film/Fernseh-Abkommen with the public broadcaster ORF. Projects follow the ORF AI guidelines in force at contract signing. Every AI system used in production must be disclosed with timecodes, and AI-generated music is not allowed.

By the delivery date, producers send ORF a timecoded script and a cut list separating self-shot, ORF archive, AI-generated and third-party material, with rights holders named. As of 23 October 2026, the ORF guidelines are at version 1.2, dated 24 July 2026.

## Why it matters

For an Austrian producer with ORF money in a film, AI use becomes a delivery item logged by timecode, not a credits line. ORF's guidelines say a credits-only label is not sufficient.

The music rule reaches composers and sound teams. ORF's guidelines allow AI-generated music on YouTube and social media, where only royalty-free music would be used, and do not currently plan it for broadcast or ORF's own online services.

## Still open

The ÖFI notice is undated. It does not say whether projects contracted before Article 50 began to apply on 2 August 2026 must file the new cut list.

## For your film

Producers negotiating an ORF contract can confirm which guideline version applies on signing and keep a timecoded AI log from the first shoot day. ORF takes questions at FilmFernsehabkommenFP6@orf.at.

## Read further

- [ÖFI notice on the AI Act and the Film/Fernseh-Abkommen (German)](https://filminstitut.at/news/ki-ai-act-auswirkungen-auf-film-fernsehabkommen)
- [ORF AI guidelines, version 1.2 (German, PDF)](https://der.orf.at/unternehmen/leitbild-werte/ki-guidelines/ki-guidelines-eu100.pdf)
- [European Commission FAQ on Article 50 transparency obligations](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act)
- [Guidelines on transparency obligations for AI-generated content](https://eugfa.org/discourse/eu-ai-act-transparency-guidelines). Official framing of Article 50 transparency rules, including how artistic and fictional deepfake-like works are treated. Essential European policy context for makers.