AI disclosure scenario
Do you need to disclose a virtual model or AI avatar?
Direct answer
Usually disclose a photorealistic virtual model or avatar. State that the model is virtual while identifying which product is real. Article 50 applies only when the final media meets the EU deep-fake definition, but TikTok and platform transparency systems can cover a broader range of realistic AIGC.
Applies when
- Article 50 focuses on whether the result resembles an existing person, object, place, entity or event and would falsely appear authentic. A model based on, or closely resembling, a real person needs both disclosure analysis and documented likeness consent.
- For a wholly fictional virtual model, the Article 50 classification can be less direct. A clear label is still the safer commercial presentation when viewers could reasonably assume that a human model was photographed wearing or using the product.
Doesn't apply when
- A clearly stylised mannequin, illustration or game-like character that cannot reasonably be mistaken for a photographed person.
- A real model photographed normally, where AI only corrects colour or removes minor background defects.
- Internal concept testing that is not published to an external audience.
Worked decision
Example
A real dress is composited onto a photorealistic generated model for an Instagram product campaign.
Decision: Disclosure recommended
The model is synthetic but the garment is real. The wording should prevent viewers from inferring a human photoshoot without mischaracterising the product itself.
Model is AI-generated. Garment shown is real.
Next steps
Required action
- Record the generated or altered component, source asset, tool and destination before publishing.
- Apply the native platform label wherever the applicable platform workflow requires it.
- Use component-specific wording such as: “Model is AI-generated. Garment shown is real.”
Publishing layer
Platform differences
Instagram and Facebook
Meta may expose AI info from detected provenance signals or self-disclosure. Component wording should distinguish the virtual model from the photographed garment or product.
Open platform guide →TikTok
Realistic AI-generated people in images or video require the AIGC label. Some unauthorised likeness and false-endorsement uses are prohibited, not cured by a label.
Open platform guide →YouTube
Use the AI-use setting for a realistic synthetic presenter or model when the content creates a scene that did not occur or depicts a real person doing something they did not do.
Open platform guide →Evidence
Source
Freshness and accountability
Last verified
Last reviewed 2026-09-12 · Current
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Copy-ready language
Disclosure wording options
Model is AI-generated. Garment shown is real.
Virtual model created with AI; product image supplied by the brand.
Related guides
“Doesn't apply” means no disclosure requirement is identified for the facts stated here. A client policy, advertising rule or another destination platform can still be stricter. This page is source-backed information, not legal advice.