Labelling AI-Generated Images in Ad Creatives

In short: Not every AI-generated or AI-edited advertising image requires a label.

Since 2 August 2026, certain AI-generated content must be labelled under Article 50 of the EU AI Act. This particularly applies to so-called deepfakes: artificially generated or manipulated depictions that misleadingly appear authentic or truthful in the advertising context.

This can include realistic depictions of people, products, actions, or product results. By contrast, a real, unaltered product shown against an AI-generated background generally does not require a label, provided it does not create a misleading impression of the product or its use.

For detailed information and practical examples, read the blog post by our partner, IT-Recht Kanzlei:
AI Images in Online Stores: 12 Practical Examples of Labelling Requirements

Please note: Our partner’s article is in German.