Classified examples · Customers and content · Po polsku
Marketing creates images with an AI image generator
Transparency (Article 50)Deployer
The marketing team generates campaign visuals and social media images with an AI tool.
How we classify it
- The company uses an AI system that generates images: deployer. The tool's vendor is the provider and must mark the output as AI-generated in a machine-readable way (Article 50(2); for tools already on the market the deadline is 2 December 2026).
- Image generation for marketing is not high-risk and not prohibited.
- If an image is a realistic depiction of people, objects, places or events that could falsely appear authentic, it is a deepfake and the company must disclose that it is AI-generated (Article 50(4)). Clearly artistic or creative work needs only a light-touch disclosure.
- Result: transparency obligations for realistic images; minimal risk for obviously illustrative graphics.
What applies now
- A labelling rule, for example 'Generated with AI' on realistic images
- Keep the provider's marking and content credentials; do not strip metadata
- No real people or their likeness without consent
- Consumer law: images must not mislead about the product
What would change the answer
- A realistic 'customer' photo used as a testimonial is misleading advertising, labelled or not
Evidence to keep
- Labelling rule
- Examples of labelled images
- Transparency checklist
In the AI Compliance Kit: 05Transparency Checklist and Disclosure Texts · 02AI Acceptable Use Policy.
Dates and sources
- Transparency obligations, Article 50: 2 August 2026
- Machine-readable marking of generative AI output: 2 December 2026
Legal basis: AI Act art. 50(2), 50(4).
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