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Labelling guide

When does an image need a label?

Four kinds of images, four answers. This guide shows which images in your store need an AI label under the EU AI Act – and which official icon to use.

The rule

The rule in one sentence

If an image was generated or manipulated with AI and could appear authentic to the viewer, you must disclose that it is AI content.

Art. 50(4) EU AI Act · applies since 2 August 2026

Four cases

Which case is your image?

These are the four answers of the Visibl decision assistant – and what follows from each.

  1. Photo
    01

    Real photo

    No label needed

    Taken with a camera, at most with classic edits like cropping, exposure or colour correction. No AI content, no obligation.

    Example: Studio shot of your product, colour-corrected in Lightroom.

  2. AI-edited
    02

    Real photo, edited with AI

    Label: AI modified

    A real photo in which AI changed or added content – a new background, removed objects, an added model. If the edit changes what the image shows, label it “AI modified”. Minor touch-ups that don’t change the content usually don’t need a label.

    Example: Product photo with an AI-generated beach background.

  3. AI-generated
    03

    AI image that looks like a real photo

    Label: AI generated

    Created entirely with AI and could pass for a real photo. This is exactly the case Art. 50(4) is about: label it “AI generated”.

    Example: Photorealistic lifestyle scene from an image generator.

  4. Illustrationoptional
    04

    AI image that is obviously not real

    Usually no obligation

    Nobody would mistake it for a photo – clearly illustrated, stylised or fantastical. Art. 50(4) covers content that appears authentic, so there is usually no obligation. A voluntary label still builds trust.

    Example: Comic-style illustration or abstract artwork.

The official icons

Which icon for which case?

AI generated
AI generatedFor images created entirely with AI that look like real photos.
AI modified
AI modifiedFor real photos whose content was substantially changed with AI.

Placement

How to show the label

  • Visible at first glance

    The label has to be clear and distinguishable at the latest when the image is first seen – not hidden in alt text or the footer.

  • Readable on every device

    Check desktop and mobile: the label must stay legible at small sizes and on busy backgrounds.

  • Wherever the image goes

    Using the image on social media, in ads or feeds? Burn the label into the file so it travels with the image.

  • Document your decision

    Keep a record of why you labelled an image – or why not. It’s your proof if anyone asks.

With Visibl

One question per image. Visibl does the rest.

The decision assistant asks exactly this question with these four answers. If the image metadata reveals an AI generator, the answer is already pre-selected – you confirm, Visibl adds the right label and logs your decision.

See the decision assistant

Decision assistant

How was this image created?

Pre-selected from image metadata (C2PA)

  • Real photo
  • Real photo, edited with AI
  • AI image that looks like a real photo
  • AI image that is obviously not real

This guide summarises the requirements in simplified form and does not replace legal advice for your individual case.

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