Who is affected

  • Marketing teams acting as deployers of generative AI systems in the EU.
  • Agencies producing campaign assets with generative components.
  • Providers of generative tools whose outputs must be machine-marked.

What triggers the rule

  • Generating or manipulating image, audio or video that resembles real persons, objects, places or events and would falsely appear authentic.
  • Publishing AI-generated text to inform the public on matters of public interest.

What does not trigger it / exceptions

  • AI-generated text that went through human editorial review where a natural person takes editorial responsibility.
  • Artistic, satirical or fictional deepfake work — disclosure still applies, but in an appropriate manner that does not hamper the work.

Scenario table

ScenarioOutcomeWhy
Synthetic voice-over on real product footageDisclosure recommendedNot automatically a deepfake unless it resembles a real person’s voice or falsely appears authentic; platform policies and client standards usually recommend disclosure.
AI video of a real-looking person endorsing a productDisclosure requiredArticle 50(4) deepfake disclosure; also a consent and rights review.
AI-generated news-style article, no human reviewDisclosure requiredArticle 50(5) public-interest text disclosure applies.

Required action

  1. Identify assets containing realistic synthetic image, audio or video.
  2. Disclose the artificial generation or manipulation clearly and distinguishably.
  3. Do not rely on tool-side metadata alone — record the decision yourself.
  4. Route identifiable-person and consent questions to human review.

Practical marketing examples

  • A campaign video with an AI-generated crowd scene that looks filmed on location — disclose the synthetic scene.
  • A cloned voice of a celebrity — do not publish; human review and rights clearance required.

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.

Not sure which scenario matches your asset?

Run the free check — result, wording and sources in under a minute.

Check this scenario

Primary sources

Frequently asked questions

Does Article 50 apply to advertising?

Yes where its triggers are met — realistic synthetic image, audio or video resembling real persons, objects, places or events must be disclosed regardless of whether the use is commercial.

Is a caption enough?

The law requires disclosure that is clear and distinguishable. Platform-native labels are the most reliable mechanism on social platforms; captions and on-asset wording can complement them.

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.