AI-generated images on social media: what EU brands have to label
Which posts need a label under the AI Act
Article 50(4) applies to deployers, meaning anyone using an AI system in their own business, so a brand posting its own content counts. The duty covers image, audio or video that is a deep fake: AI-generated or manipulated content that resembles existing persons, objects, places, entities or events and would falsely appear to a person to be authentic or truthful (Article 3(60)). The deep fake guide works through that definition in detail.
For a brand's social feed, that splits roughly like this:
| Post | Article 50(4) label? | Why |
|---|---|---|
| Photorealistic AI image of your product in a setting it was never in | Likely yes | Resembles a real object and would pass as a real photo |
| AI "customer" or model who looks like a real person | Likely yes | Resembles a person and would pass as authentic |
| AI video of a real location, such as your shop front at night | Likely yes | Resembles a real place |
| Flat illustration, cartoon or 3D-render style graphic | Usually no | Nobody would take it for real |
| Real photo with AI used only to remove a stray cable or adjust light | Usually no | The content is not generated or substantially changed |
| Clearly fantastical ad (a sneaker walking on the moon) | Reduced duty | See the creative exception below |
The last row matters for ad creative. Where the content is part of an evidently artistic, creative, satirical, fictional or analogous work, Article 50(4) limits the duty to disclosing that AI-generated content exists, in a way that does not get in the way of showing or enjoying the work. A small credit line is enough there. A campaign that looks like a real product photo is not "evidently" creative just because an agency made it.
When and how the label has to appear
Article 50(5) says the information has to be clear and distinguishable and given at the latest at the time of the first interaction or exposure, and it has to meet accessibility requirements. For social posts that means:
- Feed image or carousel: put the disclosure on the image or in the first line of the caption. Captions get cut after a line or two on most apps, so a note at the end of a long caption is not seen at first exposure. If only one slide of a carousel is AI-made, label that slide.
- Reel, Short or TikTok video: an on-screen text label at the start, and the first line of the caption.
- Story: a text sticker on the frame itself. Stories have no caption that people read first.
- Paid ads: the same rule applies to the creative. The platform's ad label is not a substitute (see below).
- Alt text: add "AI-generated image of..." to the alt text as well. It helps screen reader users, which is part of the accessibility point in 50(5), but alt text alone is not a visible label.
Plain wording works: "AI-generated image", "Made with AI", or "This scene was created with AI." Avoid wording that hides it, such as "digitally enhanced", for a fully generated scene.
The platforms' own AI labels
Each big platform has its own labelling rules. They are separate from the AI Act and are set by the platforms' terms, not by EU law.
- Meta (Instagram, Facebook). Meta shows an "AI info" label. It applies it when it detects industry-standard AI signals in the file or when the person uploading discloses it. Since September 2024, content that was only edited with AI tools has the label moved into the post's menu, while content detected as AI-generated keeps the visible label (Meta's newsroom post, updated through October 2025). For ads, trade press has reported that the disclosure sits in the "About this ad" panel. So a viewer may never see Meta's label on an ad.
- TikTok. TikTok says it requires creators to label realistic AI-generated content and that it auto-labels some content made on other platforms by reading Content Credentials (C2PA) metadata (TikTok newsroom, 2024). Auto-labelling only works if the metadata survives your editing and export.
- YouTube. YouTube requires creators to disclose meaningfully altered or synthetic content that seems realistic, through the altered-content setting in YouTube Studio. Its help page lists a real person doing or saying something they didn't, altered footage of real events or places, and realistic scenes that never happened. Clearly unrealistic or animated content, special effects and beauty filters are exempt.
Use these settings, because breaking a platform's rules can cost you reach or the post. But don't rely on them for Article 50: they may sit in a menu, they depend on metadata that editing can strip, and the duty in 50(4) is yours as the deployer, not the platform's.
Metadata: don't strip it
The machine-readable marking duty in Article 50(2) falls on the provider of the generation tool, not on the brand (see the marking guide). But your workflow decides whether that marking survives. Screenshotting an image, re-exporting it from some editors, or running it through a compressor can remove Content Credentials, which then also stops Meta and TikTok from auto-labelling it. Export from the generation tool or from an editor that keeps provenance data, and spot-check a final file with a Content Credentials inspector before you schedule a campaign.
Other EU rules still apply
The AI Act sits next to consumer law. Under the Unfair Commercial Practices Directive (2005/29/EC), a commercial practice is misleading if it deceives or is likely to deceive the average consumer about things like the main characteristics of a product. An AI image that makes a product look bigger, better made or different from what ships can be misleading whether or not it carries an AI label. The label tells people how the image was made. It does not make an inaccurate picture of the product acceptable.
A pre-posting check for social teams
- [ ] Is the image or video AI-generated or substantially changed by AI?
- [ ] Would a viewer take it for a real person, product, place or event? If yes, it needs a visible label.
- [ ] Label visible at first exposure: on the image or video, or in the first caption line.
- [ ] Platform AI setting switched on where the platform asks for it (YouTube altered content; TikTok AI-generated label).
- [ ] Content Credentials still present in the exported file.
- [ ] The image shows the product as it actually is.
- [ ] Post and label recorded in your content log.
Sources
- Regulation (EU) 2024/1689 (AI Act) on EUR-Lex: Article 3(4) (deployer), Article 3(60) (deep fake), Article 50(2), (4) and (5).
- Article 50 text at artificialintelligenceact.eu.
- Directive 2005/29/EC (Unfair Commercial Practices Directive) on EUR-Lex: Article 6.
- Meta: Our approach to labeling AI-generated content and manipulated media, with its update notes.
- Social Media Today: Meta adds updated disclosure tags for AI-generated ads, reported, for the ad placement.
- TikTok newsroom: Partnering with our industry to advance AI transparency and literacy.
- YouTube Help: Disclosing use of altered or synthetic content.