AI image disclosure
Direct answer
AI images need disclosure when they are photorealistic and generated or manipulated in ways that could falsely appear authentic — synthetic models, altered appearances, fake events or realistic generated scenes. EU AI Act Article 50(4) requires deployer disclosure for such deepfakes from 2 August 2026. Instagram, TikTok and YouTube require native AI labels for realistic AI imagery. Partial use, like generative fill around a real product, needs wording that discloses exactly the AI part.
Inspect its embedded AI signals before posting. This does not predict whether Instagram or another platform will definitely add an AI label.
Applies when
- Photorealistic fully generated images.
- Generated or altered people, faces, bodies or models.
- Generated scenes or events that look filmed or photographed.
- Generative fill that extends reality convincingly.
Doesn't apply when
- Clearly stylised, illustrated or unrealistic imagery.
- Minor retouching that does not change what the image appears to show.
Worked decision
Example
Real product, AI-generated beach background
Disclosure recommended
The product is real; disclose the generated background specifically to stay truthful and platform-safe.
Next steps
Required action
- Use the native AI label on the publishing platform.
- Word the disclosure to match the actual AI component.
- Record tool, prompt scope and approver in your AI Usage Manifest.
Publishing layer
Platform differences
Law, platform and client layers
EU AI Act Article 50(4) requires deployers to disclose realistic AI-generated or manipulated image, audio and video resembling real persons, objects, places or events. Use the platform’s native label and keep your own evidence record.
Evidence
Source
Freshness and accountability
Last verified
Applies from 2026-08-02 · Last reviewed 2026-09-10 · Current
Run this exact scenario
Relevant content, AI-use and platform inputs are preselected. Confirm the remaining facts before relying on the result.
Who is affected
- Performance agencies generating ad creative at scale.
- E-commerce teams using virtual models or generated backgrounds.
- Social teams compositing real products with AI scenes.
More scenarios
| Scenario | Outcome | Why |
|---|---|---|
| Fully generated photoreal model wearing real clothes | Disclosure required | Realistic synthetic person in commercial content — native label plus wording. |
| AI upscaling of a real photo | No disclosure identified | Enhancement does not alter what is depicted; record it in the manifest. |
Practical marketing examples
- “Background generated with AI. Product photographed.”
- “Model is AI-generated. Clothing is real.”
Related pages
Disclara separates binding law, platform policy, client policy, technical provenance and recommended wording. Information on this page is not legal advice. See editorial policy.
