AI labelling

What has to be labelled

AI labelling makes it recognisable that content was generated artificially. The legal basis is the EU AI Act, which provides a transparency duty for synthetic content. The duty applies in stages: images, video and audio produced with AI have to be labelled in every case. For text it applies to content informing the public and published without editorial review.

An important distinction follows. A product text written with AI support and then reviewed by a specialist is editorially processed and does not fall under the duty. A blog post taken unchecked from a model does.

Which forms are permissible

The regulation does not prescribe a design, only that the disclosure is perceptible. Four forms are common and can be combined. The visible note on the page or directly on the image. The note in metadata that search engines and platforms read. The marking inside the file itself, which some providers insert automatically. And the note in the alt text, which works for screen readers and crawlers.

The last point is the most common and at the same time the weakest. Alt text is not read by sighted visitors. Anyone wanting to meet the duty needs at least a visible note, even if it is styled discreetly.

What is workable in a shop

• Images: a short note on the image, inside it or in the caption. With items where the image is meant to show the product, care is needed, because a note can suggest the product is fictional.
• Blog and glossary: one line below the post or a note in the author line is enough and can be set automatically.
• Product copy: the duty usually does not apply here, because the text is reviewed. The note is sensible anyway when customers value it.
• Advertising: as soon as a motif was produced with AI the note belongs with it, regardless of channel.
• Technical implementation: cleanest is a field per image or post from which the note is rendered, rather than maintaining it by hand.

Why alt text alone is not enough

The AI Act requires the disclosure to happen in a way that is perceived. Alt text is made exactly for being read out by assistive tools and is not displayed on screen. It works for screen readers and search engines, not for the sighted visitor. Anyone setting only the alt text documents the intent but does not fully meet the duty.

In practice this is the point where a lawyer should be involved before AI images are used broadly in a shop. The assessment depends on the individual case, and the regulation becomes applicable in stages.

Frequent questions

• Do I have to label every edited image? Only when it was generated or substantially changed with AI.
• Is a note in the privacy policy enough? No, it has to be perceptible on the content itself.
• Does the duty apply to translations? With machine translation the labelling question is open, and reviewing is the safe route.