Synthetic content labeling under the EU AI Act

What is synthetic content?

Synthetic content refers to audio, images, or video that is artificially generated or manipulated by AI systems. This includes:

• AI-generated images (e.g., from Midjourney, DALL-E, Stable Diffusion)
• AI-generated video (e.g., from Sora, Runway, Synthesia)
• AI-generated audio (e.g., voice synthesis, music generation)
• AI-manipulated media (e.g., face swaps, voice cloning, background replacement)

Who has obligations?

Providers

Providers of AI systems that generate synthetic content must:

1. Ensure outputs are marked in a machine-readable way
2. Make outputs detectable as artificially generated

This means the AI system itself should embed metadata, watermarks, or other technical markers. This is a provider obligation — it applies to the company that builds the AI system.

Deployers

Deployers who publish synthetic content must:

1. Disclose that the content is artificially generated or manipulated
2. For deepfakes specifically, disclose that the content has been artificially generated or manipulated

What counts as a deepfake?

A deepfake is AI-generated or manipulated content that resembles real persons, places, or events and would appear authentic to a reasonably well-informed person.

Examples:

• A video showing a real person saying something they never said
• An AI-generated image of a real person in a situation that didn't happen
• A voice clone of a real person speaking words they never spoke

How to label synthetic content

Images

"This image was generated using artificial intelligence."

Place as a caption, alt text, or visible watermark.

Video

"This video contains AI-generated content."

Place at the start of the video and in the description.

Audio

"This audio was produced using AI voice synthesis."

Place in the audio introduction and in the content description.

Deepfakes (stronger wording)

"This content has been artificially generated and may not depict real events."

When labeling is not required

• Personal, non-professional use
• Content obvious to a reasonably well-informed person as AI-generated
• Artistic or creative content (disclosure must not hamper the work, but some form of disclosure is still expected)

The Commission's code of practice

The Commission's code of practice on transparent AI, published in June 2026, provides further guidance on how providers should mark synthetic content.

The full labeling guide

The Labeling Kit (€99) includes a complete labeling guide, wording library, decision tree, and record log for all types of synthetic content.