Guide · Compliance
The EU AI Act and your campaign imagery
From 2 August 2026, brands deploying AI-generated imagery of people in the EU must disclose that AI was used. Here is what changes for fashion and e-commerce teams, in plain language.
What Article 50 requires
The AI Act’s transparency obligations (Regulation (EU) 2024/1689, Article 50) apply to “deep fakes” — AI-generated or manipulated image, audio or video content that resembles real people, places or events and could falsely appear authentic. A photoreal AI image of a person in a campaign meets that definition. Deployers must disclose that the content was artificially generated or manipulated, and providers of generative systems must mark outputs as AI-generated in a machine-readable format. The Commission’s Code of Practice on the transparency of AI-generated content, published 10 June 2026, sets out accepted labeling methods.
Consent and disclosure are different layers
A common misreading: “our model consented, so no label needed.” Consent governs likeness rights — whether the person agreed to appear. Disclosure governs what the viewer is told — that AI produced the image. They are separate obligations, and a compliant campaign needs both. The practical difference is in what the label says about your brand: “AI-generated; this person doesn’t exist” reads very differently from “AI-produced imagery featuring our contracted model, who approved it and is paid for its use.”
The compliance checklist
- Inventory where AI-generated imagery of people appears: PDPs, paid social, email, OOH.
- Apply a visible disclosure where required — your ad units and product pages, not your vendor’s job.
- Prefer imagery that carries machine-readable marking (C2PA Content Credentials) so platforms label it correctly and automatically.
- Keep a consent and rights record per image — the likeness layer regulators and platforms increasingly expect alongside the AI label.
FAQ
When do the EU AI Act's transparency rules take effect?
Article 50's transparency obligations apply from 2 August 2026. The European Commission published a supporting Code of Practice on the transparency of AI-generated content on 10 June 2026.
Do AI images of real, consenting models still need disclosure?
Yes. Disclosure and consent are separate legal layers. Article 50 covers AI-generated content that resembles real people and could appear authentic — regardless of consent. Consent solves the likeness-rights question; disclosure tells the viewer AI was used. Compliant campaigns need both.
What are the penalties for non-compliance?
Article 50 violations sit in the tier of fines up to €15 million or 3% of global annual turnover, whichever is higher.
What is machine-readable marking?
Providers of generative AI systems must mark outputs as AI-generated in a machine-readable format — for example C2PA Content Credentials, a signed manifest embedded in the image file that platforms and compliance tools can read automatically.
How Mirai handles this
Every image generated on Mirai features a real, licensed model — consented, image-approved, and compensated. Mirai keeps server-side consent and licensing records today; machine-readable C2PA content credentials and public verification pages are in development and not yet in every licensed download.
This guide is general information, not legal advice. Facts current as of July 2026 — verify against the official texts before relying on them.