AI Labeling — Checklist
Compact overview: when to label, label examples, channel tips.
LabelNot requiredBorderline / special case
Rule of thumb: it's not about "AI yes/no", but about the impression of authenticity. Metadata or watermarks alone are not enough. The notice must be visible/audible to people.
Content type. Basic rules
| Content / use | Required? | Note |
|---|---|---|
| Fully synthetic AI images (Midjourney, DALL·E, Stable Diffusion, AI lifestyle mockups) | YES | AI-generated, often looks realistic |
| AI-manipulated images/videos/audio (generative fill, background swap, remove/add objects, ML skin smoothing) | YES | AI alters image content → deepfake risk |
| Classic image editing without AI (color, light, contrast, cutout, pixel-based retouching) | NO | No AI model used |
| Product photos, only technically optimized (noise reduction, exposure, sharpening, neutral background) | NO | Substantive content unchanged |
| Product photos, content altered (objects/people/places/situations added, removed, recolored) | YES | Alters authenticity |
| Schematic graphics, infographics, icons (recognizably graphic, not a real photo) | NO | No deceptively realistic reference |
| Virtual models / usage scenes that look like real photos | IN DOUBT | Could be mistaken for a real photo |
| Motifs on T-shirts, mugs, etc. | ONLY IF REALISTIC | Photorealistic/authentic-looking → Yes · Abstract/stylized → No |
| AI voice / AI voice-over (product video, ad, podcast) | YES | Audio deepfake. Notice at the start + in the video |
| AI chatbot / AI assistant on a website | YES | Users must recognize AI at first interaction (unless obvious) |
| Pure product/ad copy, instructions, FAQs | NO | Not a matter of public interest. Usually no obligation |
| AI text on matters of public interest (politics, health, science) | YES | Exception: human-reviewed + editorial responsibility named |
Online shop. Scenes
| Scene in the shop | Required? | Practical tip |
|---|---|---|
| Main image: AI-generated lifestyle mockup | YES | Label directly on the image |
| Detail view: cutout only, color correction | NO | Classic editing |
| Size/usage example (model on sofa, AI background) | YES | If a realistic photo |
| Schematic diagrams (dimension sketch, icon set) | NO | Obviously graphic |
| Before/after (wrinkles/smoothing, body shapes) with AI | YES | Significantly alters authenticity |
| Review photos, AI-retouched (skin, lighting, background) | YES | AI manipulation + realistic impression |
| 360° view with AI additions (missing angles generated) | YES | AI fills in content |
| AR try-on / room placement (AI-based) | YES | Synthetic overlay, looks real |
| Trust elements (logos, certificates). AI-faked | SPECIAL CASE | No AI Act obligation, but risky under competition law |
Campaign & social media
| Campaign element | Required? | Note |
|---|---|---|
| Social post image (AI-generated, realistic) | YES | Deepfake logic |
| Social post image (illustration / comic / abstract) | NO | Obviously artificial |
| Influencer content with AI model/person (photorealistic) | YES | Could be mistaken for a real person |
| Display banner with AI photo (person/place/usage scene) | YES | Label visible in/near the banner |
| Video ads with AI narrator or virtual model | YES | Audio and/or visual deepfake |
| Video ads with classic post-production (cut, color, no AI) | NO | No AI generation/manipulation |
| YouTube description / post caption as the only notice | NO. Not enough | Notice must be visible on the content itself |
| Chat ads / conversational ads (AI bot) | YES | Recognizable as AI at first interaction |
| Social post text on public-interest topics (news, politics, health) | YES | Exception: editorially responsible |
| Pure product advertising, promo, sale | NO | Not a matter of public interest. Usually no obligation |
Print & offline
| Print element | Required? | Why / how |
|---|---|---|
| Flyer / poster with AI photo (person/place/scene, realistic) | YES | Deepfake logic also applies offline |
| Flyer / poster with illustration / 3D render (obviously artificial) | NO | No deceptively realistic impression |
| Product catalog: AI lifestyle scenes (living room, model) | YES | Label in/near the image |
| Packaging: AI-generated motif (person/place/event) | YES | Notice on/near the packaging |
| Packaging: abstract pattern, icons, typography | NO | Obviously not real |
| Print ad (newspaper/magazine) with AI photo | YES | Label in the image area or caption |
| Inserts with AI-voice QR video | YES | Notice in the video / QR landing page |
| Synthetic testimonials / expert statements (AI person/AI voice) | YES | Deceptively real person/opinion |
| Clearly "fictional scenes" (cartoon, comic, obviously staged) | NO | Obviously artificial/fictional |
Phone & interaction
| Scenario | Required? | Implementation |
|---|---|---|
| Outgoing calls with AI voice / AI assistant | YES | State clearly at the start of the call |
| Hotline with AI voice bot | YES | "You are connected to an AI assistant." |
| Human agent with AI tools (transcript, suggestions, no AI voice) | NO | User is speaking with a human |
| AI voice that sounds like a known person | YES + RISK | Clear notice + check unfair-competition and personality-rights law |
Internal & special cases
| Scenario | Required? | Required? |
|---|---|---|
| Internal AI tools without publication | NO | — |
| Internal reports / presentations | NO | — |
| Legacy content from before 02 Aug 2026, unchanged online | NO | — |
| Legacy content re-published / changed | CHECK | — |
Internal & special cases
| Scenario | Required? | Required? |
|---|---|---|
| Product with an AI feature (chatbot, image generator) | YES | — |
| Software/code generated by AI | NO | — |
| High-risk AI (medicine, scoring) | OTHER OBLIGATIONS | — |
| Labeling replaces rights clearance | NO | — |
How to label — web & print
🌐 Web (shop, landing page, social)
- Label directly on the image/video or immediately below it
- In the visible product area. Not in the T&Cs or at the end of the description
- Videos: label at the start + repeat regularly
- Audio: spoken notice at the beginning
- EU icon set optional, but icon + text recommended
- Caption/description alone is not enough
🖨 Print (flyer, catalog, packaging)
- Notice in/near the image or as a caption
- Packaging: label, tag, insert or back
- If artistic/fictional: more discreet, but present
- QR video: notice in the video itself or on the landing page
- Same deepfake logic as online
📞 Phone & chat
- AI call: state clearly at the start
- Chatbot: recognizable at first interaction
- Wording: "You are speaking with an AI-driven assistant"
✍ Text
- Pure ad copy: usually no obligation
- Unless the ad itself informs about public-interest topics (health, politics): then label it
- Exception: human-reviewed + a responsible person named
AI-generated imageAI GENERATEDAI MODIFIEDAI-generated voiceThis video contains AI-generated content
Checklist before publishing
- AI use identified (generation or content manipulation)?
- Content is being published (not just internal)?
- Checked for authenticity impression. Does it look like a real photo/person/place/voice?
- If required: notice placed clearly, understandably and visibly/audibly?
- For video/audio: notice at the start (not only at the end)?
- For print: notice in/near the motif or on the packaging?
- Rights checked (personality, copyright, trademark law). Labeling does not replace this?
- Accessibility: sufficient contrast, alt text for screen readers?
Legacy content: content published before 02 Aug 2026 that remains unchanged does not need to be labeled retroactively. Re-published or substantially changed → check again.
Orientation based on the EU AI Act (Art. 50). Not legal advice. For borderline cases consult a qualified lawyer. Effective from 02.08.2026 · ai-act-checker.com