Labelling AI content on TikTok

What TikTok requires

Posts

According to its newsroom (19 November 2025), TikTok requires people to label realistic AI-generated content, with tools in the app. TikTok also detects AI through C2PA Content Credentials and its own detection models. If content is edited elsewhere and reuploaded, such data can be lost; TikTok is therefore testing invisible watermarks as an extra layer.

Ads

Under the ads policy (as of April 2026), heavily edited or AI-generated content may only run with the AIGC label or your own clear disclosure. According to TikTok, minor changes such as lighting, brightness, colour, removing or changing the background, and denoising are exempt.

How this relates to your Article 50 duty

Anyone who uses an AI system professionally to generate or manipulate image, video or audio content that is a deep fake must disclose it (Article 50(4) AI Act). A retailer is that deployer when it, or a contractor working to its instructions, uses AI for product or advertising images (guidelines, paras. 12 and 14). The duty follows the image, not the platform: it applies in your own store just as on a marketplace. Whether an image is affected is answered by the labelling check.

TikTok's exceptions are not the same as the guidelines'. Under the guidelines, a purely decorative AI background behind a real product generally does not need a label; a background that creates a deceptive scene can, however. Check every creative under Article 50, even where TikTok does not require a label.

TikTok is on the Commission's list of very large online platforms. Under the guidelines, deployers may rely on such a platform's labelling tools within that platform if the tools allow a clear and distinguishable disclosure, and only in the context of that platform (para. 126). How far this carries for a given tool is not settled. A platform label that appears only sometimes, or only after a click, does not automatically replace your own visible disclosure.

Steps

1. Check every AI creative with the labelling check.
2. Posts with realistic AI content: add TikTok's AI label when uploading.
3. Ads: add the AIGC label or your own clear disclosure in the creative, for example with Label an AI image.
4. Keep C2PA Content Credentials in your files. They help TikTok detect AI.

Not legal advice. Platform rules change; the platform's current wording is what counts. A label does not make a misleading image lawful.

Not legal advice. This content explains the law based on primary sources; it does not replace an assessment of your individual case.