If synthetic media looks real, check the deepfake duty
Deepfakes are AI-generated or manipulated image, audio or video content that resembles existing people, objects, places, entities or events and would falsely appear authentic or truthful. The definition is narrower than anything made with AI.
Who this applies to
- Fashion and retail brands using synthetic models that resemble real people
- Advertisers using AI voices or presenters that could be mistaken for authentic recordings
- Teams publishing face swaps or realistic AI-altered scenes
- Deployers publishing third-party deepfake media through their own channels
What the regulation requires
Article 50(4) requires deployers using an AI system to generate or manipulate deepfake audio, image or video to disclose that the content was artificially generated or manipulated. For evidently artistic, creative, satirical, fictional or analogous work, disclosure must still be appropriate and cannot hamper display or enjoyment of the work.
Implementation steps
- 1Identify AI-generated or manipulated people, voices, objects, places and events.
- 2Check whether each asset meets the Act's deepfake definition rather than applying a blanket rule.
- 3Apply a clear, distinguishable and accessible disclosure at the latest on first exposure.
- 4Record the asset, wording, channel, owner and publication date in your implementation file.
Common implementation gaps
- Believing profile-level wording automatically covers each separately published asset.
- Ignoring republished synthetic media because another party generated it.
- Relying only on hidden metadata where Article 50(4) calls for disclosure to people.
The assessment
Company assessment
€99
One payment per company.
Get a specialist-reviewed AI inventory, system classifications, required notices and a prioritised action plan within 24–48h.
What you receive
- •AI inventory and system classifications
- •Article 50 duties by touchpoint
- •Recommended notice wording and placement
- •Evidence and documentation gaps
- •Prioritised actions and deadlines
- •Specialist review and follow-up questions
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