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Craig Solomon
Craig Solomon

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C2PA Content Credentials and the Chain-of-Custody Gap

Content Credentials are having a moment. Samsung Galaxy S25 and Google Pixel 10 sign media natively at the camera level. Adobe, Google, Meta, Microsoft, and OpenAI are all behind the standard. The EU AI Act Article 50 mandates machine-readable content marking by August 2, 2026, and C2PA is the compliance path the industry has converged on.

For insurance and legal professionals, this matters. A C2PA credential embedded in an image records who captured it, when, with what device, and what processing was applied. That provenance metadata travels with the file and can be verified independently.

But it has a limitation the claims and legal audience needs to understand.

The credential lives inside the file.

During a platform re-upload, a format conversion, or a routine file transfer, that metadata can be stripped. Not maliciously, necessarily. A workflow tool that doesn't preserve XMP metadata. A CMS that recompresses images on upload. A PDF conversion that drops sidecar data. The credential is gone, and the chain of custody has a gap, with no record it ever existed.

In a claims context, that gap is significant. If an insured submits property documentation through three different software tools between capture and submission, and one strips the C2PA data, you're reviewing an unverified file. The provenance that existed at the moment of capture no longer exists at the moment of review.

A blockchain anchor solves a different problem. ProofLedger computes a SHA-256 hash of the file at the moment of anchoring and records that fingerprint on Polygon (confirmed instantly) and Bitcoin (daily batch with merkle proof). The original files stay on the device. What gets recorded is a cryptographic commitment to the file's exact state at a specific point in time.

That record exists on a public ledger. No platform touches it. No file transfer strips it. No party to the dispute controls it. If the file changes at all after anchoring, the hash won't match, and the mismatch is itself evidence.

The strongest documentation chain uses both layers. C2PA says: here is where this file came from, how it was captured, and what was applied to it. A blockchain anchor says: this file existed, in this exact state, before this date. Together, they address different attack vectors. Neither substitutes for the other.

For court authentication, FRE 901(b)(9) covers evidence produced by a process that generates an accurate result. FRE 902(13) is the self-authentication standard for machine-generated records, allowing written certification without live witness testimony. Risk managers and outside counsel who understand these rules can design documentation workflows around them before a dispute, not in response to one.

C2PA compliance addresses the EU regulatory question. Blockchain anchoring addresses the chain-of-custody question. They're related, but they're not the same question.

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