AI image disclosure
Applies from 2026-08-02 · Last reviewed 2026-09-10 · Current
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.
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.
What triggers the rule
- 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.
What does not trigger it / exceptions
- Clearly stylised, illustrated or unrealistic imagery.
- Minor retouching that does not change what the image appears to show.
Scenario table
| Scenario | Outcome | Why |
|---|---|---|
| Real product, AI-generated beach background | Disclosure recommended | The product is real; disclose the generated background specifically to stay truthful and platform-safe. |
| 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. |
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.
Practical marketing examples
- “Background generated with AI. Product photographed.”
- “Model is AI-generated. Clothing is real.”
Relation to platform policy
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.
Run the free check — result, wording and sources in under a minute.
Primary sources
Related pages
Methodology: Disclara answers are generated from a versioned rule set citing primary sources, reviewed by humans. Information on this page is not legal advice. See sources & methodology and rule changelog.