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AI Act check

What does this look like in practice?

These examples show typical cases. The outcome always depends on the specific content, the publication context and the role of the user. Voluntary labelling remains possible even where no legal obligation applies.

Example 1 · disclosure normally required

Real person in a fabricated scene

The newly generated AI image shows former Pope Francis in a situation that never took place. The depiction looks like an authentic photograph. What triggers the obligation is that the image was generated on or after 2 August 2026 – the well-known original motif from 2023 would not itself require retroactive disclosure.

Legal assessment

Where published professionally or by an organisation, disclosure is normally required. Purely personal, non-professional use falls under the private exception in principle.

Deepfake under Article 3(60); disclosure under Article 50(4).

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Example 2 · disclosure normally required

Photorealistic scene for an invented event

The AI depiction shows people, a place and an event as though they were an authentic recording. In the specific publication context this can create the impression that the event is taking place or has already taken place. A purely graphic poster using symbols and text would not usually be a deepfake – see example 3.

Legal assessment

Where published professionally or by an organisation, disclosure is normally required. Purely personal, non-professional use falls under the private exception in principle.

Deepfake assessment under Article 3(60); disclosure under Article 50(4).

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Example 3 · normally no obligation

Graphics, symbols and text

The advertising poster consists of recognisable graphics, symbols and lettering. It does not simulate an authentic recording of a real person, place or event.

Legal assessment

Even in professional use there is normally no disclosure obligation under Article 50(4). Purely private use is exempt in any case.

The four cumulative criteria of the deepfake definition are normally not met.

Assess separately

This assessment concerns the rule on images. Where the graphic contains unreviewed AI text on a matter of public interest, the rule on texts must be assessed separately. Advertising and ordinary product descriptions do not normally fall under it; claims of public relevance may well do so.

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Example 4 · depends on the context

Photorealistic landscape of a plausible place

The landscape is invented but looks like a genuine photograph of a place that could exist.

Legal assessment

Where published professionally or by an organisation, disclosure is normally required, provided the depiction could be taken as authentic or truthful in the specific context. Purely personal, non-professional use falls under the private exception in principle.

Deepfake assessment under Article 3(60); disclosure under Article 50(4).

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Example 5 · must be disclosed

Automatically published text on a public matter

The AI text deals with a political or otherwise publicly relevant matter and was published without substantive human review.

Legal assessment

Where published publicly, disclosure is required. Purely internal texts, private correspondence or purely personal use do not fall under this particular case.

Article 50(4) for AI-generated or manipulated texts on matters of public interest.

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Example 6 · no obligation

AI text with genuine editorial review

The text was checked on the merits, sources were verified, and an editorial team holds editorial and legal responsibility.

Legal assessment

No disclosure obligation under this provision, provided the review was substantive and the published final version was actually approved.

Exception under Article 50(4) where there is human review or editorial control and clear accountability.

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This set of examples offers journalistic orientation on the EU AI Act and does not replace individual legal advice. What governs is the specific case, the regulation as it applies and its interpretation.