The EU’s AI labelling rules are now in force. A practical guide for marketers

Article 50 of the EU AI Act, the part that deals with transparency, has applied since 2 August 2026 [1]. If your campaigns reach people in the EU, it applies to you even if your business is based in the UK [1].

What has to be labelled

• Deepfakes. If you use AI to create or manipulate images, audio or video that look real (a person, place or event), you must disclose it clearly, at the latest when someone first sees it. A hidden watermark on its own isn’t enough; the label has to be visible to people [1].

• AI-generated text on public-interest topics. Text published to inform the public on matters like health, consumer safety or the economy needs labelling too [1].

• Chatbots and assistants. People should know when they’re talking to an AI system [2].

The creative exemption

Evidently artistic, creative, satirical or fictional work gets a lighter touch: you still disclose, but in a way that doesn’t spoil the work [1]. That helps a stylised campaign film. It doesn’t cover a realistic ‘customer testimonial’ generated by AI.

What to do this quarter

• Add an ‘AI used?’ field to every creative brief and asset record.

• Agree a standard on-screen and caption label for AI-generated or manipulated assets.

• Check your tools: if a platform adds a disclosure, make sure your workflow doesn’t strip it out [3].

• Keep a simple log of how assets were made. It’s the fastest way to answer a client or regulator question.

Fines can reach €15 million or 3% of worldwide annual turnover [3], but the bigger risk for most brands is trust. Being open about AI is easier when it’s built into the process from the brief.

Sources

1. Transparency obligations under Article 50 of the AI Act, European Commission

2. Code of Practice on transparency of AI-generated content, European Commission

3. The EU AI Act’s transparency rules: a practical guide to Article 50, artificialintelligenceact.eu

We build these checks into the work we do for clients, so approvals, labels and disclosure are handled before anything goes live. Our FAQ covers how approvals work.