AI-generated visuals have become part of everyday marketing, social media and e-commerce. Businesses are using them to create advertising assets, product backgrounds, people, interiors and even entire scenes that never existed in real life. This raises an increasingly important question: do these images need to be labelled? <\/p>\n\n
Since 2 August 2026, transparency requirements under Article 50 of the EU AI Act<\/a> have applied to certain types of AI-generated and manipulated content. The aim is to make it clear when content that appears authentic has actually been created or altered using AI. <\/p>\n\n The most important point is that not every image created or edited with AI needs a visible label.<\/p>\n\n For businesses, one of the most relevant parts of the AI Act concerns so-called deepfake content.<\/p>\n\n Under the regulation<\/a>, a deepfake is AI-generated or manipulated image, audio or video content that resembles an existing person, object, place, entity or event and could falsely appear to be authentic or truthful.<\/p>\n\n In practice, this could include:<\/p>\n\n The European Commission<\/a>, for example, gives the example of a genuine photograph of an empty apartment that is furnished using AI in a way that makes the final image look like an authentic photograph.<\/p>\n\n In these situations, a business using the content needs to consider whether it should clearly disclose that the image was generated or manipulated using AI. Article 50 of the AI Act<\/a> requires those deploying deepfake content to disclose its artificial nature.<\/p>\n\n In short: no.<\/p>\n\n The fact that AI was used somewhere in the editing process does not automatically mean the image falls under the deepfake disclosure requirement.<\/p>\n\n European Commission guidance<\/a> indicates that standard editing assistance may fall outside the scope of the transparency requirements for AI-generated or manipulated content.<\/p>\n\n So if AI is used only for minor retouching, colour correction, noise reduction or a similar technical adjustment, and it does not materially change what the image depicts, it is not treated in the same way as realistic synthetic or substantially manipulated content.<\/p>\n\n The more useful question is not \u201cWas AI used?\u201d, but rather \u201cDid AI change the content in a way that could make someone believe they are seeing something authentic?\u201d<\/p>\n\n The AI Act<\/a> also makes specific allowances for artistic, creative, satirical, fictional and similar works.<\/p>\n\n Where deepfake content forms part of an obviously creative or fictional work, the transparency requirement still applies, but the disclosure can be presented in a way that does not interfere with the enjoyment or presentation of the work.<\/p>\n\n This means a realistic advertising image and an obviously fantastical AI illustration will not necessarily be treated in exactly the same way.<\/p>\n\n There are two separate responsibilities to understand.<\/p>\n\n First, providers of AI tools are responsible for technical measures that make it possible to identify content as AI-generated or AI-manipulated.<\/p>\n\n However, if a business publishes that content and it falls within the definition of a deepfake, technical marking alone is not enough. The audience must also be clearly informed that the content has been generated or manipulated using AI.<\/p>\n\n Put simply: the AI provider is responsible for technical marking, while the business publishing the content is responsible for clearly informing the viewer when disclosure is required.<\/p>\n\n The EU has already published official AI content labels<\/a> that businesses can use free of charge. Their use is optional, but they can provide a practical way to make it clear that an image has been generated or altered using AI. <\/p>\n\n However, adding an icon does not automatically mean a business is fully compliant with every requirement under the AI Act.<\/p>\n\n If you use AI-generated visuals regularly, you also do not need to create every label manually.<\/p>\n\n Shopify stores can use the EU AI Icons & Labels<\/a> app, which allows merchants to label AI-generated or edited product images and control how those labels are displayed on the site.<\/p>\n\nWhen does an AI-generated image need to be labelled?<\/strong><\/h2>\n\n
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Does every AI-edited image need to be labelled?<\/strong><\/h2>\n\n
What about creative or obviously fictional images?<\/strong><\/h2>\n\n
Who is responsible for labelling AI-generated images?<\/strong><\/h2>\n\n
How can AI-generated images be labelled in practice?<\/strong><\/h2>\n\n