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 — and licensed downloads carry signed C2PA Content Credentials marking them AI-generated, with a public verification page per license. The disclosure requirement is packaging, not a problem.
This guide is general information, not legal advice. Facts current as of July 2026 — verify against the official texts before relying on them.