An AI disclosure has two layers: the short label at the image (“AI” with “AI-generated” or “AI-modified”) and an explanation of what was changed, for example “Modified: the background. Unchanged: the product.” The Code of Practice encourages the explanation; it makes the label precise.
Why precise texts help
“AI-enhanced” or “symbolic image” do not disclose that an image was artificially generated or changed, so they are not enough. Someone who reads “Unchanged: the product” knows the product looks as shown. How labels affect willingness to buy is covered in AI labels and conversion.
The building blocks
- Label text next to “AI”. The Code of Practice (Measure 1.1 b) encourages the local language.
- Second layer with heading and explanation, opens when the label is clicked.
- Alt text suffix for screen readers, such as “ (AI-generated)”. Article 50(5) requires an accessible disclosure.
- aria-label for the label, if you build it yourself.
- Widget attributes, if you use the widget.
“Unchanged: the product” is your statement of fact. Only use it when it is true. A label does not make a misleading image lawful (recital 137 AI Act).
Frequently asked questions
How do I word an AI disclosure for a product image?
The image shows “AI” with “AI-generated” or “AI-modified”. The explanation says what was changed and, if true, what stayed unchanged.
Is a note in the product description enough?
No. The disclosure has to be at the image, clear and distinguishable, at the latest when it is first seen. A note only in texts, terms or an info page is not enough under the guidelines (para. 142).
Can I write the label in my own language instead of “AI”?
The Code of Practice uses the English acronym “AI” as the main element. Your language's text goes next to it.
Sources
Para. refers to the paragraph number in the European Commission's guidelines on Article 50, C(2026) 5054.
- Code of Practice on Transparency of AI-Generated Content (final version)Europäische Kommission · Code of practice · 10 Jun 2026
- Regulation (EU) 2024/1689 (AI Act)EUR-Lex · Law · 12 Jul 2024
- Commission Guidelines on the transparency obligations under Article 50 AI Act, C(2026) 5054 finalEuropäische Kommission · Commission · 20 Jul 2026
- W3C, Web Content Accessibility Guidelines (WCAG) 2.1W3C · Standard · 5 Jun 2018
