AI images and videos in your marketing: a label sheet for small EU businesses (Article 50(4), 2026)
What you get: a finished AI content label sheet you can paste into Google Sheets or Excel: one row per image, video, voice clip or article you publish, with what the AI did, whether it could pass as real, the label you used, and who signed it off. Plus a 3-question test and ready-to-use label wording for posts, ads, video and audio. It is built for Article 50(4) of Regulation (EU) 2024/1689, which applies from 2 August 2026.
Does this post need a label? The 3-question test
The Commission's Article 50 FAQ explains that content is a deepfake (Article 3(60)) only when three things are all true. Ask them in order for every AI image, video or audio you are about to publish.
- Resemblance: does it closely resemble a person, object, place, entity or event?
- Existing or plausible: does that person, place or event exist, or could it plausibly exist or have existed?
- False appearance: would your audience, in this context, take it as authentic or truthful?
Three yeses mean a visible or audible label at the latest when people first see or hear it (Article 50(4) and 50(5)). If any answer is no, write the reason in the sheet so you can show your thinking later.
| Typical small-business use | Label? | Why |
|---|---|---|
| Photorealistic AI "customer" or "staff member" in an ad or testimonial | Yes | Resembles a plausible real person and is meant to look real. Also check consumer law: a made-up customer endorsing you can mislead buyers on its own. |
| AI-generated photo of your shop, product in use, or an event that never happened | Yes | Looks like a real place or event and would be taken as genuine |
| Cloned voice of a real person in a radio ad, reel or phone message | Yes | Audio resembling an existing person; get that person's written consent too |
| Product photo with background swapped or tidied by AI | Depends | Fine-tuning or background clean-up may not create a false impression; if the setting implies something untrue (a store you don't have, a celebrity holding it), label it |
| Clearly cartoon, illustrated or stylised artwork | Usually no | Unlikely to "falsely appear authentic"; note the reason in the sheet |
| Satire, fiction or an obviously creative piece that uses realistic AI | Lighter label | Article 50(4) limits the duty to a disclosure that does not spoil the work, such as a credit line or end card |
| AI-drafted blog or newsletter text, reviewed and approved by a named person who takes editorial responsibility | Usually no | The text rule covers public-interest information without human review or editorial control; keep the reviewer's name and date |
| AI-written article on a public-interest topic (health, consumer safety, local politics) published with no human review | Yes | Falls inside the Article 50(4) text rule |
Content you published before 2 August 2026 does not have to be labelled after the fact, according to the Commission's transparency quick facts, though labelling it is encouraged.
Who does what
- You, as deployer (the business that publishes the content): the human-visible label under Article 50(4).
- Your AI tool's provider: machine-readable marking under Article 50(2). For generative tools already on the market before 2 August 2026, the Digital Omnibus gives providers until 2 December 2026. That mark does not replace your label: the Commission FAQ says deployers cannot rely on it.
- The platform (Instagram, YouTube, TikTok and others) may have its own AI label or disclosure setting. Use it as well, but keep a visible label in the post itself so it travels when the content is shared.
The label sheet (copy and fill in)
AI content label sheet · Business: [name] · Owner of this sheet: [name, role] · Reviewed: [monthly / per campaign]
| Publish date | Asset and channel | AI tool | What the AI did | 3-question test (Y/N/N) | Label needed? | Label wording and placement | Approved by |
|---|---|---|---|---|---|---|---|
| [dd/mm/yyyy] | [e.g. Instagram ad, autumn sale] | [tool name / version] | [generated whole image of a model wearing our jacket] | [Y / Y / Y] | [Yes] | ["AI-generated image" bottom-left on the image + platform AI label] | [name, date] |
| [dd/mm/yyyy] | [e.g. website product page] | [tool] | [removed background, no new objects] | [Y / Y / N] | [No] | [none: real product, real photo, background cleaned only] | [name, date] |
| [dd/mm/yyyy] | [e.g. 20-second reel] | [tool] | [cloned founder's voice for voice-over, with written consent] | [Y / Y / Y] | [Yes] | [spoken at start: "This voice is AI-generated" + caption] | [name, date] |
| [dd/mm/yyyy] | [e.g. blog post] | [tool] | [first draft of text] | [text: reviewed by a person?] | [No, reviewed] | [editor: name; responsibility: company] | [name, date] |
Monthly check: posts with AI content this month: [n] · labelled: [n] · "no label" reasons all written: [yes / no] · new AI tools added: [list] · next review: [date]
Keep one sheet per business (or per brand). Add a row before the asset goes live, not afterwards. If an agency makes content for you, ask them to fill the same columns and send the sheet with each delivery.
Ready-to-use label wording
| Format | Short label | Where to put it |
|---|---|---|
| Image or ad | "AI-generated image" or "Image created with AI" | On the image itself, readable on a phone, not only in the caption |
| Edited photo | "Photo edited with AI" | On the image or the first line of the caption |
| Video | "This video contains AI-generated scenes" | On screen in the first seconds; for a long video, repeat it or keep a corner tag |
| Audio or voice | "This voice is AI-generated" | Spoken at the start, plus text where the audio is shown |
| Creative or satirical work | "Made with AI" in the credits or end card | Where it doesn't spoil the work (Article 50(4) second subparagraph) |
| Public-interest article with no human review | "This article was generated with AI" | At the top, before the text |
Article 50(5) asks for the information to be clear and distinguishable and given at the latest at first exposure. A label hidden in hashtags or at the end of a long caption is weak.
Checklist before you publish AI content
- Every AI tool you use for images, video, voice or text is in your AI inventory (SME AI inventory template)
- Row added to the label sheet, with the 3-question answers or the text-review note
- Real person's likeness or voice used only with their written consent; no AI testimonials presented as real customers
- Label visible on the asset itself, plus the platform's AI setting where it has one
- Staff who make content know the rule: the AI-literacy duty under Article 4 has applied since 2 February 2025 (AI literacy guide)
- Chatbots and voice bots have their own "you are talking to AI" notice (Article 50 chatbot checklist)
- Nothing sexual or intimate is generated of a real person without consent; the Digital Omnibus adds a ban on AI practices for generating non-consensual intimate content
This sheet is a starting point, not a legal opinion or proof of compliance. Advertising, consumer-protection, image-rights and data-protection rules in your country can add more. Fines for breaching Article 50 can reach €15 million or 3% of worldwide annual turnover, and for SMEs the lower of the two applies (Article 99(4) and 99(6)). Spot an error in this guide? Write to mininglife7@gmail.com.
For accountants and tax advisers
Many small clients now run AI-made ads and reels without thinking about labels. At your next review, ask "do you publish AI images, videos or voices, and who checks them?", note the answer with a date, and hand them this sheet. It fits next to the client AI inventory workshop. Stay inside your professional rules and pass legal questions to a lawyer.
Keep the record with your AI register
The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. Add each image, video or voice tool, mark its transparency duty, and store the date of your latest label sheet review as an evidence record.
When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.
Partner programme opening soon
Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.
Free start: list your image, video and voice AI tools in the EURO AI Register free edition, then add this month's label sheet date. Related: Article 50 chatbot checklist · Staff AI use policy · Prohibited AI practices list.
Sources
- Regulation (EU) 2024/1689 (AI Act): Articles 3(60), 4, 50(2), 50(4), 50(5), 99(4) and 99(6)
- European Commission: Transparency obligations under Article 50 (FAQ)
- European Commission: Quick facts on transparency rules for AI systems
- Council of the EU: AI Act timeline (Digital Omnibus, 29 June 2026)
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.