# Do you have to disclose AI-generated content, and who requires labels?

Source: https://forum.global100.org/q/do-you-have-to-disclose-ai-generated-content-and-who-requires-labels/
Site: Global 100 Forum, category Policy, law and disclosure
Published: 2026-09-20. Updated: 2026-09-25. Replies: 1.

## Question by Tomas Reyes (staff), 2026-09-20

Increasingly yes, depending on where you publish and what the content is. The EU AI Act makes disclosure of deepfakes a legal obligation, YouTube and TikTok require labels on realistic AI media, Meta labels on detection or self-disclosure, and the US FTC treats AI-driven impersonation as fraud under existing rules. Plain text is the least regulated.

## The legal baseline: EU AI Act Article 50

[Article 50](https://artificialintelligenceact.eu/article/50/) of the EU AI Act is the only broad, binding labelling law in a major market, applying from 2 August 2026 under Article 113. It stacks four duties: chatbots must make clear the user is dealing with an AI; providers of systems generating synthetic audio, image, video or text must mark outputs in a machine-readable, detectable way where technically feasible; deployers who create deepfakes must disclose it, with a lighter duty for evidently artistic or satirical work; and AI text published to inform the public on matters of public interest must be disclosed unless a person holds editorial responsibility for it.

The Commission's Digital Omnibus text gives systems on the market before 2 August 2026 until 2 December 2026 to meet the marking duty.

## Platform rules: YouTube, TikTok and Meta

[YouTube](https://support.google.com/youtube/answer/14328491) requires creators to disclose, via the "AI use" setting in YouTube Studio, content that makes a real person appear to say or do something they did not, alters footage of a real event, or generates a realistic scene that never happened. Unrealistic content and minor edits (filters, AI-written scripts, cloning your own voice) need no disclosure. YouTube may label content itself when it carries C2PA metadata, and that label cannot be removed; persistent non-disclosure risks removal or Partner Program suspension.

[TikTok](https://support.tiktok.com/en/using-tiktok/creating-videos/ai-generated-content) requires labels on all realistic AI-generated images, audio or video, auto-labels content carrying C2PA Content Credentials, and does not let creators remove an auto-label. Some AI content is banned regardless: fake crisis events, fake authoritative sources, and the likeness of under-18s or private adults without permission.

Meta's [April 2024 policy post](https://about.fb.com/news/2024/04/metas-approach-to-labeling-ai-generated-content-and-manipulated-media/) chose labels over removal: Facebook, Instagram and Threads apply an "AI info" label on detecting industry-standard AI indicators or on self-disclosure, from May 2024 for organic content. Political and social issue advertisers have had to disclose digital alteration in certain cases since January 2024.

## The United States: no label law, but deception rules apply

No general US law requires AI labels; the tool is enforcement against deception. In February 2024 the [Federal Trade Commission](https://www.ftc.gov/news-events/news/press-releases/2024/02/ftc-proposes-new-protections-combat-ai-impersonation-individuals) finalised its rule on government and business impersonation and proposed extending it to individuals, citing voice cloning and deepfakes. Undisclosed AI is not itself illegal there; using it to impersonate a real person or company is.

## C2PA: the label that travels with the file

[C2PA](https://c2pa.org/) publishes an open standard, Content Credentials, recording a file's origin and edits in signed metadata; its steering committee includes Adobe, Google, Meta, Microsoft, OpenAI and TikTok, and it is the obvious route to the marking Article 50 demands. Its limits are in [the C2PA thread](/q/what-is-c2pa-and-do-content-credentials-actually-help/): the data is optional and stripped by screenshots. Text has no container for it and relies on [watermarking](/q/does-watermarking-ai-generated-text-actually-work/) instead.

**Who requires AI labels, on what, and since when**

| Who requires it | What must be labelled | From when |
| --- | --- | --- |
| EU AI Act, Article 50 | Chatbots, machine-readable marks on synthetic output, deepfakes, public-interest AI text | 2 August 2026; marking grace to 2 December 2026 for existing systems |
| YouTube | Realistic content altering real people, events or places, or inventing scenes | In force; C2PA auto-labels cannot be removed |
| TikTok | All realistic AI-generated images, audio and video; some banned outright | In force; C2PA auto-labels cannot be removed |
| Meta | Content with industry AI indicators or self-disclosed; altered political ads | May 2024; political ads January 2024 |
| US FTC | No label duty; impersonation of government, business and (proposed) individuals is actionable | February 2024 |
| C2PA Content Credentials | Voluntary provenance metadata from tools and cameras | Open standard; read by YouTube and TikTok |

## What that means in practice

- **Realistic is the trigger.** A fantasy scene needs no label; a real-looking person or event does.
- **Decide before upload.** If the file carries C2PA data, YouTube and TikTok will label it, permanently.
- **Text is the gap.** Only the EU rule touches AI text, and only for public-interest publishing.
- **Disclosure does not launder deception.** A label does not make a fake endorsement lawful.

## Reply 1 by Tomas Reyes (staff), 2026-09-25

A workflow point for anyone publishing AI-assisted media regularly: export with provenance intact rather than screenshotting the result, and decide up front whether you want the platform's automatic label or would rather self-disclose in your own words. The two are not equivalent. An auto-label from C2PA data is locked; a self-disclosure can be edited and can carry context such as "voice cloned from my own recording". For work heading to EU audiences after August 2026, keeping the machine-readable mark on the file is also the simplest way to show the Article 50 duty was met.

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Cite as: Global 100 Forum, "Do you have to disclose AI-generated content, and who requires labels?", https://forum.global100.org/q/do-you-have-to-disclose-ai-generated-content-and-who-requires-labels/, accessed 2026-10-11.