Use a short, visible label that says what AI did: “AI-generated image” for an image created as a whole, or “AI-modified” (and, when useful, what changed) for a human-made image materially altered with AI. Place the notice on or beside the image so people see it on first exposure. Provenance metadata such as Content Credentials can add useful history, but it is not a substitute for a visible label where one is required—and it may not survive sharing.
Choose wording that describes the image accurately
Make the extent of AI involvement clear instead of relying on a vague label such as “Made with AI.” C2PA’s user-experience guidance recommends source disclosures that distinguish fully generated content from partially edited content and describe the process objectively.
| What happened | Suggested label | What the label communicates |
|---|---|---|
| The image was generated as a whole with AI. | AI-generated image | The image itself was created with AI. |
| A human-made image was materially changed with AI. | AI-modified image | The image has a human-made source but was changed with AI. |
| A specific part was generated or changed. | Background generated with AI | Identifies the AI-affected element when that detail is useful to viewers. |
These are practical wording suggestions, not quoted statutory phrases. Routine assistive editing is not automatically the same as generating or materially altering an image; describe the actual change rather than applying a label that overstates what AI did.
Put the notice where people encounter the image
Use readable text on the image or immediately beside it. The European Commission’s Article 50 guidance and Code of Practice says the disclosure should be clearly perceivable and distinguishable no later than first exposure. A viewer should not need special tools or a separate action to find it. Avoid placing it where another overlay hides it, and consider whether it remains visible when the image is shared or downloaded.
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- Use plain language, adequate contrast, and a size that can be read at the image’s expected display size.
- For digital publication, make the disclosure available to people using assistive technology, for example through an accessible text equivalent when the image label is presented visually.
- If an icon is used, ensure it is understandable in context. The Commission offers optional icon variants, but using an icon alone does not establish compliance.
Visible labels and provenance solve different problems
A visible notice tells the audience directly that an image was generated or changed with AI. Machine-readable provenance can provide additional information about an asset’s creation and editing history, but it may require compatible software or a platform interface to inspect. The EU AI Act likewise separates provider machine-readable marking from a deployer’s visible disclosure duty for covered deepfakes; the European Commission says machine-readable marking alone does not meet that visible duty.
| Approach | What it is for | What to watch for |
|---|---|---|
| Visible text or a clearly understood icon | Communicating the disclosure to people at first exposure. | Placement, legibility, context, and visibility after sharing matter. |
| Content Credentials or other machine-readable provenance | Recording information about how and when content was created or modified. | Manifests can become detached or removed; viewers may not see the information without compatible support. |
C2PA’s version 2.4 technical specification, published in April 2026, includes a machine-readable AI Disclosure Assertion. If the editing or creation software supports Content Credentials, preserve them through export and publishing, then check the published asset. C2PA documents workflows where manifests become decoupled or removed; its soft-binding guidance describes supported ways to recover a related manifest using a watermark or fingerprint, not a guarantee that any particular platform will do so.
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What the EU AI Act requires for images
As of 4 October 2026, the relevant EU deployer disclosure rule is not a blanket requirement to label every image touched by AI. Article 50 requires deployers to disclose covered “deepfake” image, audio, or video content. The Commission defines a deepfake as AI-generated or manipulated content that resembles existing persons, objects, places, entities, or events and would falsely appear authentic or truthful. For a specific image, consider both what it depicts and whether it could create that false impression.
The Commission’s Article 50 FAQ says deployers must disclose deepfake content to a natural person no later than first exposure. The disclosure must be clear, distinguishable, understandable, and perceptible; a machine-readable mark that a person cannot readily see is not enough to satisfy this deployer duty.
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Artistic, creative, satirical, and fictional work
Where deepfake content forms part of an evidently artistic, creative, satirical, fictional, or analogous work or programme, the disclosure must be presented appropriately without hampering the work’s display or enjoyment. This tailors how the disclosure is presented; it does not make the Commission’s optional icon a compliance guarantee.
Dates and transition
The relevant Article 50 provisions apply from 2 August 2026. The Commission describes a limited transition until 2 December 2026 for provider marking and detection obligations involving AI systems placed on the market before 2 August 2026. It also says content generated before 2 August 2026 need not be labeled retroactively, though labeling is encouraged where possible. These timing provisions do not turn the deployer’s deepfake disclosure rule into a requirement to label every AI-assisted image.
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A practical publishing workflow
- Identify the AI contribution. Decide whether the image was generated as a whole, materially modified, or changed only in a specific element. Choose a label that describes that distinction.
- Add a visible disclosure. Put the phrase on or next to the image where it is noticeable at first exposure. Check contrast, size, overlays, and accessibility in the actual layout.
- Preserve provenance if supported. Keep Content Credentials through export and publication as a second layer of information, not as a replacement for visible wording.
- Inspect the published version. Check the image after upload and, where relevant, after download or repost. Confirm the visible label remains available and that provenance is still attached or otherwise accessible.
- Check legal context and audience. If publishing in the EU, assess whether the image meets the deepfake definition and whether the tailored treatment for an evidently artistic, creative, satirical, fictional, or analogous work applies.
Do not assume a platform will label every image
Platform handling can change, and available evidence does not establish a current, comprehensive comparison of how services label AI images. C2PA reported on 5 September 2024 that Meta used Content Credentials to inform AI-image labels on Facebook, Instagram, and Threads. That dated report does not show that all images on those services are labeled today or that credentials survive every upload and repost path. Check the image as your audience will see it rather than relying on a platform’s label or metadata handling.
The European Commission says more than 187 participants from industry, academia, civil society, rightsholders, EU Member States represented in the AI Board, and external observers took part in developing its voluntary Code of Practice. The Code supports implementation, but adherence is voluntary and does not replace the AI Act.
Quick Recap
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