YouTube requires the “AI use” disclosure in YouTube Studio when realistic content was generated or meaningfully altered with AI.
According to YouTube, unrealistic content, minor aesthetic edits and production assistance such as scripts or thumbnails are exempt. Your check under Article 50 of the AI Act is not affected by this.
What YouTube requires
According to YouTube Help, creators disclose realistic content that was generated or meaningfully altered with AI. YouTube's examples are a real person who appears to say or do something they didn't, altered footage of a real event or place, and a generated realistic scene that didn't occur.
According to YouTube, these are exempt:
- unrealistic content, such as fantastical scenes,
- minor, primarily aesthetic edits such as beauty filters, colour and lighting adjustments or upscaling,
- production assistance such as a script, outline, thumbnail or title.
You set the disclosure when uploading in YouTube Studio, in the attributes under “AI use”. YouTube may also apply a label itself, for example to content with C2PA metadata, content made with YouTube's own AI tools, or after its own detection.
How this relates to your Article 50 duty
Deep fakes that you generate or manipulate with AI in your business, or have a contractor create to your instructions, must be disclosed (Article 50(4) AI Act, guidelines paras. 12 and 14). This applies in your own store and on every platform.
An AI thumbnail counts as production assistance at YouTube. If it shows a realistic scene or person, it can still be a deep fake under Article 50.
The Commission lists YouTube as a very large online platform. There, deployers may rely on the platform's labelling tools under para. 126 of the guidelines if they allow a clear and distinguishable disclosure. How far this carries is not settled, especially for notices that appear only sometimes or only after a click.
Steps
- Check the video and the thumbnail with the labelling check.
- When uploading in YouTube Studio, set “AI use” to yes if the video contains realistic AI content.
- If the thumbnail needs a label, put it into the image, for example with Label an AI image.
- Keep C2PA metadata in your files.
Not legal advice. The current wording of the platform rules is what counts. A label does not make a misleading image lawful.
Frequently asked questions
Do I have to label an AI product video on YouTube?
Yes, with “AI use”, if it looks realistic and was generated or meaningfully altered with AI. Whether it is a deep fake under Article 50 is a separate check.
Does this apply to AI thumbnails?
YouTube requires no disclosure for thumbnails. Under Article 50, a realistic AI thumbnail can still need a label.
Sources
Para. refers to the paragraph number in the European Commission's guidelines on Article 50, C(2026) 5054.
- YouTube Help: disclosing altered or synthetic contentGoogle · Platform · 11 Oct 2026
- European Commission: list of designated very large online platforms and search enginesEuropäische Kommission · Commission · 7 Sept 2026
- Commission Guidelines on the transparency obligations under Article 50 AI Act, C(2026) 5054 finalEuropäische Kommission · Commission · 20 Jul 2026
- C2PA Technical Specification 2.2Coalition for Content Provenance and Authenticity · Standard · 1 May 2025
