Yes, a label is required. The guidelines name face replacement, substantial facial modification and altering body shape or skin colour as changes of content (para. 92). The image does not show the person as they are (para. 113 iv). You will usually also need the model's consent, and the label does not replace it.
Labelling required
A replaced face or changed body shape, skin colour or facial features are changes to the content. The image does not show the person as they are.
Rn. 92 · Rn. 113 iv
AI changes to real people usually require their consent. The label does not replace it.
This classification follows the European Commission's guidelines on Article 50 AI Act. The guidelines are not binding; only the Court of Justice of the EU can interpret the law bindingly. You make the decision.
The example
After a shoot, a sportswear store uses AI to swap the model's face and make the waist slimmer. The leggings stay unchanged.
The answers in the labelling check
- Was an AI tool used to create or change this image?
Yes - Who used the AI tool?
Me or someone on my team - When was the image created or last changed with AI?
On 2 August 2026 or later - What did the AI do to this image?
It created, inserted or changed a person, such as a model, face, skin, body or pose. - How is the person shown?
Realistically, like a real human - What did the AI do with the person?
Face replaced, or body shape, skin colour, age or facial features clearly changed - Is the image itself part of an artwork, satire or fiction, and is that immediately obvious to everyone?
No, it is an advertising or product image
Adapt these answers in the labelling check
When the result changes
- If the AI only fixed small things unrelated to the product, such as red eyes or a bit of lint, a label is generally not required under the guidelines (paras. 92, 116).
- If the correction is small but shows what your product does, a label is required (skin retouching for cosmetics).
- For a person generated entirely by AI, see AI model.
- If the changed body shape also makes the fit look different, the image can be misleading even with a label (para. 129).
What to do
- Clarify the model's consent for this change.
- Put the “AI” label with the words “AI-modified” on the image, wherever it appears.
How the disclosure can read
AI-modifiedLabel: AI · AI-modified
AI-modified image
This photo was modified with artificial intelligence (AI). Modified: the person's face or body.
Create the text in 24 languages · Add the label to the image
Frequently asked questions
The model agreed to the edit. Do I still need the label?
Yes. Consent concerns the model's rights; the label informs customers. Both apply side by side (paras. 124, 129).
What if the model was only made to look a bit younger?
That is also a clear change. In the context of film, the guidelines name de-ageing as an example of a deceptive depiction of persons (para. 114).
Sources
Para. refers to the paragraph number in the European Commission's guidelines on Article 50, C(2026) 5054.
- Commission Guidelines on the transparency obligations under Article 50 AI Act, C(2026) 5054 finalEuropäische Kommission · Commission · 20 Jul 2026
- Regulation (EU) 2024/1689 (AI Act)EUR-Lex · Law · 12 Jul 2024
- Code of Practice on Transparency of AI-Generated Content (final version)Europäische Kommission · Code of practice · 10 Jun 2026
