Labeling of AI Content: Obligations from August 2026

EU AI Act

Labeling of AI Content: What Obligations Apply from August 2026

July 21, 2026

    From August 2, 2026, new transparency obligations for certain AI systems and AI-generated or AI-manipulated content will apply in the EU. Affected are direct interactions with AI, certain image, audio, and video content, as well as texts on topics of public interest.

    For companies, it is relevant in what role they use AI: as providers or operators. Providers of generative AI systems must generally mark generated or manipulated texts, images, audio, and video content in a machine-readable way. Companies that use such systems in the course of their professional activities are regularly considered operators. For them, visible disclosure obligations can particularly arise in the case of deepfakes and certain text publications.

    For marketing teams, there are three main areas of interest:

    • In the case of chatbots and similar applications, it must be ensured that users are informed that they are interacting with an AI system, unless this is already obvious from the circumstances.

    • For images, audios, and videos, companies must disclose that a content is artificially generated or manipulated when it is considered a deepfake. This refers to content that depicts people, objects, places, or events so realistically that they can be falsely perceived as real. However, it is currently somewhat controversial what exactly is understood by deepfakes.

    • For AI-generated or AI-manipulated texts, labeling may be required when they are published to inform the public and concern matters of public interest, such as political, social, or health issues, as well as economic developments that are the subject of public debate. The labeling obligation does not apply if the content has been examined or editorially controlled by a human, and a person or organization assumes editorial responsibility for the publication. A purely technical or superficial release is unlikely to suffice. The review should relate to the substantive accuracy and responsible publication and be internally regulated traceably.

    Our recommendation for marketing teams is to address the following questions: Where are texts, images, audio content, or videos created or modified using AI? Who is responsible for the release and editorial responsibility for them?

    This article provides a simplified overview and does not replace legal advice.

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