Labelling your AI-generated visuals: the EU's official icons and how to build them into your brand guidelines.
If an AI-generated visual of your brand could pass for a real photo of a person, a product or a place, you must disclose it visibly. To do it properly, the European Commission provides three official icons, free to use and with no attribution required. Using them is optional; the disclosure is not. For an SME, the real task is knowing which images are concerned and setting a simple rule in its brand guidelines.
The AI Act transparency rules have applied since 2 August 2026, the Commission reminds us. On 20 July it published guidelines full of advertising examples, then a dedicated page on labelling icons, updated on 13 October. And generation tools already on the market have until 2 December 2026 to mark their content technically, under the digital omnibus regulation.
For a Belgian SME producing its posts, banners or product photos with an AI tool, the question is no longer legal but graphic: where to place the label, in what form, and on which visuals. The general legal framework is covered in our article on the AI Act transparency obligation. Here, we talk design.
Using them is optional; the disclosure is not.
The three icons offered by the Commission
The Commission's page presents three icons: a basic icon, a fully AI-generated icon and a partially AI-modified icon. Each comes in four versions (black, white and two 50% black and white variants), downloadable as SVG and PNG.
The neutral colours are deliberate: the icon must sit on any visual without breaking your identity. The guidelines recommend standardised visual cues, and an icon recognised from one country to the next beats a home-made symbol nobody understands.
One technical point matters: the invisible watermark added by some tools (C2PA metadata, SynthID marking) does not replace the visible disclosure, the guidelines state. It is the reader who must be informed, not just a machine.
Which of your brand visuals are concerned
The obligation targets the deepfake as defined by the regulation: content that resembles real persons, objects, places or events and would falsely appear authentic. The Commission's guidelines give examples very close to an SME's daily work.
No label needed
- Standard retouching: cropping, colour correction, dust removal, resizing.
- A background extended or replaced by AI for aesthetic reasons, around a real product, as long as the ad does not mislead about that product.
- A clearly fanciful illustration, such as talking animals in an ad, or a blog pictogram.
Label required
- A generated product photo that could mislead about the product's real appearance, features or use.
- A realistic portrait of a team, a customer or a witness who does not exist.
- A CEO avatar or virtual influencer presenting your services: the guidelines explicitly refuse to treat them as artistic work.
If an agency produces your visuals without you controlling its use of AI, the agency is responsible for the label, according to the guidelines. Better to put that in writing in the contract.
Building the label into your brand guidelines
A label placed at random, in a different spot every time, looks improvised. Treat it like your logo: an element of your brand guidelines, with fixed rules.
- One single position: the same corner on every format, away from the logo and buttons, inside each network's safe zone.
- A minimum size: readable on a phone without crushing the visual. Test it on a square post and a story.
- The right version: black icon on light backgrounds, white on dark ones, never recoloured in brand colours.
- Supporting text: ‘AI-generated image’ under the photo or in the caption, translated into French and Dutch if your site is.
The disclosure must appear at the latest at the first exposure, Article 50 specifies. A note at the bottom of your legal notice page is therefore not enough. On Meta or YouTube, the platform's labelling tool can help, but the responsibility remains yours.
What you risk without a label
The maximum fine for transparency breaches is 15 million euros or 3% of worldwide turnover. For an SME, the lower of the two amounts applies, under Article 99 of the regulation. In Belgium, the list of market surveillance authorities published by the Commission still showed no Belgian authority on 9 November 2026.
The real risk lies elsewhere: a customer who finds out that a ‘real’ photo was not mostly remembers that the brand cheated. And a label does not make misleading advertising lawful, the guidelines recall. A topic close to that of logos created with AI: the tool saves time, trust is managed separately.
Frequently asked questions
Do I need to label visuals published before 2 August 2026?
No. According to the Commission, content published before that date is not covered by the obligation, although labelling is still encouraged. Do think, however, about visuals you republish or recycle today.
Can I recolour the icon in my brand colours?
The four versions supplied are neutral so they stay recognisable everywhere. Recolouring them blurs that shared cue. Keep the black or white version depending on the background.
Does a photo of my real product on an AI-generated set need a label?
In principle no, based on the examples in the guidelines, as long as the set does not mislead about the product itself. If the set suggests a use or a result the product cannot deliver, the answer changes.
Priority action plan
- List your AI-generated or AI-modified visuals published since 2 August 2026.
- Sort them into three piles: minor retouch, set or fanciful illustration, realistic visual to label.
- Download the official icons and fix position, size and wording in your brand guidelines.
- Write into your agency or freelance contracts who applies the label, and on which media.
A brand that owns its AI visuals, with a clean label always in the same place, inspires more trust than a brand hoping nobody will notice. It is a design detail, but also a sign of professionalism.
Want brand guidelines that also cover your AI visuals? We build your visual identity with these rules built in.
