Deepfake disclosure
Direct answer
Under Article 50(4) of the EU AI Act, a deepfake is AI-generated or manipulated image, audio or video that resembles existing persons, objects, places or events and would falsely appear authentic or truthful. Deployers must disclose that the content is artificially generated or manipulated. For evidently artistic, satirical or fictional work, disclosure must still happen, but in a way that does not hamper display of the work. The obligation applies from 2 August 2026.
Applies when
- Content resembles an identifiable person, real place or real event.
- A viewer could reasonably believe the content is authentic.
- Voice cloning or appearance alteration of real people.
- Realistic synthetic scenes presented as recordings.
Doesn't apply when
- Content that is clearly unrealistic and not resembling real persons, objects, places or events falls outside Article 50(4).
Disclosure still applies, but its form is adapted
- Evidently artistic, creative, satirical or fictional deepfake work still needs disclosure; the manner should be appropriate to the work and not hamper its display or enjoyment.
Worked decision
Example
AI avatar presenting a product
Disclosure required
Realistic synthetic person could falsely appear authentic; platform labels plus clear wording.
Next steps
Required action
- Disclose artificial generation or manipulation clearly and distinguishably.
- Use the platform-native label where available.
- Keep evidence of what was generated, with which tool, and who approved it.
- Obtain consent before using identifiable people’s likeness or voice.
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 2026-09-26 · 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
- Agencies producing synthetic spokespersons, avatars or voice clones.
- Social teams altering real footage of people or events.
- Legal reviewers assessing consent and likeness risk.
More scenarios
| Scenario | Outcome | Why |
|---|---|---|
| De-aged or retouched actor face | Human review required | Alteration of an identifiable person’s appearance — consent and wording must be reviewed by a human. |
| Cartoon-style AI illustration | No disclosure identified | Evidently fictional and unrealistic; not resembling real persons, objects, places or events. |
Practical marketing examples
- Synthetic spokesperson reading a script — label the avatar and the synthetic voice.
- AI video “from” a product launch that never happened — disclose the synthetic event.
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.
