Labelling AI content on YouTube

What YouTube requires

According to YouTube Help, creators disclose realistic content that was generated or meaningfully altered with AI. YouTube's examples: a real person appears to say or do something they didn't; footage of a real event or place is altered; a realistic scene is generated that didn't occur.

According to YouTube, these are exempt:

• unrealistic content, such as fantastical scenes,
• minor, primarily aesthetic edits such as beauty filters, colour and lighting adjustments or upscaling,
• production assistance such as a script, outline, thumbnail or title.

You set the disclosure when uploading in YouTube Studio, in the attributes under “AI use”. YouTube may also apply a label itself, for example to content with C2PA metadata, content made with YouTube's own AI tools, or after its own detection.

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.

YouTube's exceptions follow its own rules. An AI thumbnail counts as production assistance at YouTube. If it shows a realistic scene or person, though, it can still be a deep fake under Article 50. Check thumbnails separately.

YouTube 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 the video and the thumbnail with the labelling check.
2. When uploading in YouTube Studio, set “AI use” to yes if the video contains realistic AI content.
3. If the thumbnail needs a label, put it into the image, for example with Label an AI image.
4. Keep C2PA metadata in your files.

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.