Artificial intelligence has quickly become part of everyday marketing, helping businesses generate ideas, improve workflows and produce engaging visual content. From concept images and property visuals to social media campaigns and website assets, AI tools are opening up new creative possibilities.
However, as the use of AI-generated content continues to grow, new European regulations are introducing additional requirements around transparency. Under the EU AI Act, companies and marketers publishing realistic AI-generated or significantly modified content aimed at audiences in the European Union may need to clearly indicate when it’s has been created or altered using artificial intelligence.
These requirements are part of a wider European approach to helping people recognise when they are viewing AI-generated or manipulated content that could be considered misleading or, in the worst cases, used as part of a scam.
As reported by The Guardian, the rules focus particularly on realistic content that could reasonably be mistaken for genuine photographs, videos or events. Importantly, this does not mean that every image created or edited using AI requires an AI label.
These requirements should not be confused with standard photo and design editing, such as adjusting colours, improving lighting, correcting exposure or straightening an image, which has been common practice for years. These types of improvements are not considered to be the same as creating or significantly changing the content itself.
The key questions are:
Has AI changed what was photographed, filmed or experienced?
If the answer is yes, the content should be labelled.
When should AI-generated content be labelled?
For businesses using AI within their marketing, the following examples are useful guidelines:
· Realistic AI-generated images or videos
If an image or video has been created using AI and shows realistic people, properties, locations, products or events that appear genuine, it should include an AI label. For example, an AI-created image of a luxury villa, a person or a destination that looks like a real photograph needs to be clearly identified as AI-generated.
· AI-modified photographs
If an original photograph has been significantly modified using AI, the final content may also require an AI label. For example, if an original photograph shows an empty apartment but AI has been used to add furniture, views or architectural features that do not exist, the image should be labelled as AI-modified. This is because the changes could lead viewers to believe that these elements were present when the photograph was originally taken. This is particularly relevant for industries such as real estate, where images are often used to help buyers visualise a property and lifestyle.
· Minor edits do not usually require a label
Minor edits do not usually require an AI label. Normal photography and design adjustments are treated differently, and changes such as colour correction, brightness and exposure adjustments, image cropping, straightening, noise reduction, and standard retouching would not normally require an AI label, provided they do not materially change the content of the original image.
Where the label should appear
The AI disclosure should not be hidden within captions, metadata or information that requires multiple clicks to access. The label should be visible when the content is first viewed.
For different types of marketing content, this means:
- Social media posts and advertising images
A small but readable label such as “AI-generated” or “AI-modified” should be placed directly on the image or creative.
- Videos and Reels
The disclosure should appear from the beginning of the video and remain visible long enough for viewers to read it.
- Carousel posts
If only certain slides contain AI-generated or AI-modified content, those individual slides should be labelled rather than adding one general notice at the end.
- Website images
The label should appear directly on the image or immediately next to it, ensuring users see the information at the same time as the visual content.
- Paid advertising
If the advertising platform does not provide its own visible AI disclosure, the label should be added directly to the creative.
What about social media platforms?
Some platforms are already introducing their own AI information labels. If a platform clearly displays an “AI-generated”, “AI-modified” or similar notification when users first see the content, an additional label on the creative won’t be necessary. However, it’s important to check that the platform label is actually visible.
It is also important to consider if and how the content will be reused. For example, an image uploaded to Instagram may later be used on a website, in a newsletter, in printed marketing material or on another platform where the original AI label (automatically added on the social media platform) is no longer visible. To avoid uncertainty around whether the platform label will remain visible, it is advisable to add an “AI-generated” or “AI-modified” label directly to the asset itself.
What does this mean for Redline clients?
At Redline, we use AI as one of many creative tools. It can help with brainstorming, improving efficiency and developing ideas, but it is important that its use remains completely transparent.
For example, when creating real estate marketing materials, an AI-generated lifestyle image or an AI-staged property photograph can set the scene for buyers. But it is important that they are not misled into believing it is a bona fide photo, and therefore should be labelled accordingly.
An empty apartment staged with AI-added furniture should be clearly marked as AI-modified because the furniture was not present at the time of the photoshoot. However, standard editing of a photo’s lighting or colour correction doesn’t need to be labelled, as the original scene hasn’t been materially changed. In other words, there is no misrepresentation.
How we will work with our clients going forward
To ensure we continue creating content that follows the latest requirements, Redline will shortly introduce a simple AI content consent form for all clients. The form will allow you to confirm that you are aware of the requirement to disclose the use of AI, whether you wish to use AI-modified or AI-generated images in your marketing, and whether you would like the relevant disclosure labels applied.
Where AI has been used in a way that requires labelling, Redline will follow the approach confirmed in your consent form and apply this to the relevant creative assets. By completing the form, you acknowledge that disclosure requirements may apply. If you choose not to include the recommended disclosure, Redline will follow your instructions; however, responsibility for that decision and including ensuring compliance with any applicable requirements will remain with you.
Our aim is to make this process as straightforward as possible, while helping all clients use new creative technologies in a responsible and informed way.
Looking ahead
AI will continue to play an important role in the creative landscape, offering businesses new ways to communicate, visualise ideas and connect with their audiences. At Redline, we will continue using these tools thoughtfully while ensuring our clients have the information they need to make informed decisions about their marketing materials.
If you are unsure whether a specific image, video or campaign requires an AI label, our team will be happy to review it and provide guidance before publication.
Stay ahead in the changing world of AI.
Redline Company helps businesses navigate new digital trends, create engaging content and adapt their marketing strategies for the future. Get in contact with Redline Company at [email protected] or call +34 952 816 678.
FAQs
Do all AI-generated images need to have an AI label?
No. Not every image created or edited with AI requires a label. The law mainly applies to realistic AI-generated or significantly modified content that could be mistaken for a real person, place, product or event. Simple creative assistance, such as generating ideas or making minor edits, does not usually require disclosure.
Do AI property images need to be labelled?
Yes, if AI has been used to create a realistic image of a property, location or lifestyle scene, or to add elements that were not present in the original photograph. For example, an AI-staged image showing enhanced views, furniture or other features that do not exist should be clearly marked as AI-modified.
Can I use AI-generated images in my marketing without adding a label?
Businesses should consider whether the content could mislead viewers into believing it is a real photograph or genuine representation. If AI has created or significantly changed the image, a visible AI label should be included where required. Transparency helps businesses maintain trust with their audience and follow evolving regulations.
Who is responsible for AI labels in marketing content?
Businesses publishing marketing content are responsible for ensuring their materials comply with applicable requirements. When working with agencies or creative partners, it is important to agree how AI-generated or AI-modified content will be identified and disclosed before publication. Clear processes help ensure everyone understands their responsibilities.
