Disclose AI when it generates or materially changes realistic video in a way that could alter a viewer’s understanding of who or what appears, or whether an event happened. Put the notice where viewers can see or hear it when they encounter the footage, and say what AI changed. The exact legal duty depends on the platform, jurisdiction, and your role; there is no single disclosure phrase for every video.
When should you disclose AI-generated video?
Use a disclosure when realistic AI-generated or meaningfully altered footage could be mistaken for a real person, place, event, or endorsement. This includes synthetic scenes presented as documentary footage, a real speaker whose voice or lip movements were altered, or a generated character presented as a customer.
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Routine assistance such as editing does not automatically make every video subject to disclosure. Consider what the audience could reasonably infer from the finished video: if the AI involvement changes the meaning or apparent authenticity of a material scene or claim, explain it.
- Viewer notice: Can someone notice the disclosure at first exposure, rather than only after searching a description?
- Specificity: Does it identify what was generated or altered?
- Context: Could the footage otherwise be taken as evidence of a real person, event, place, or endorsement?
- Platform and jurisdiction: Does the upload service or the law where you publish impose a particular duty?
How to write a clear disclosure
Use plain language and describe the change, not just the tool. These are practical examples, not official required wording:
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- “This scene was generated with AI; it does not depict a real event.”
- “The background and crowd were AI-generated; the interview is real.”
- “AI was used to alter the speaker’s voice and lip movements.”
Place the notice next to the relevant footage or claim, using an on-screen label or spoken explanation where appropriate. A description-only note can be easy to miss, and some rules specifically require a viewer-facing disclosure. Keep provenance information or machine-readable marks where available, but do not treat them as a replacement for a notice people can understand.
What YouTube requires
YouTube requires creators to disclose realistic AI-generated or meaningfully AI-altered content using YouTube Studio’s “AI use” setting. Labels may appear in the player for photorealistic material or in the expanded description for non-photorealistic or animated content. Check the current YouTube disclosure instructions when uploading, since platform interfaces and policies can change.
YouTube may also label content automatically if it was made with certain YouTube generative tools, carries C2PA metadata, or is detected by its systems. Its May 27, 2026 update said labels for photorealistic and meaningfully altered or generated content would move to more prominent positions: below long-form video players and as an overlay on Shorts. The update said the disclosure label alone does not change recommendations or monetization eligibility. YouTube also says repeated failures to disclose may result in enforcement action.
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EU disclosure duties from 2 August 2026
The European Commission’s Article 50 FAQ distinguishes the duties of AI providers from those of deployers—the people or organizations using an AI system. From 2 August 2026, covered providers must ensure AI-generated or manipulated content is marked in machine-readable form and detectable. Deployers must disclose deepfake content to people no later than first exposure, in a clear, distinguishable way that can be perceived without special tools or extra action. The Commission’s Article 50 FAQ explains the framework.
For this provision, a deepfake is AI-generated or manipulated image, audio, or video that resembles existing or plausibly existing people, objects, places, entities, or events and appears authentic or truthful. The assessment can depend on context, intended audience, resemblance, and the content’s message. Machine-readable marking is a provider-side obligation; by itself, it does not meet the deployer’s viewer-facing disclosure duty.
The Commission says the Article 50 obligations apply from 2 August 2026. For qualifying systems placed on the market before that date, only the provider marking and detection duties receive a transition, applying from 2 December 2026. Content created before 2 August 2026 does not have to be labelled retroactively under this provision, although the Commission encourages labelling where possible. Its guidance describes an appropriate-manner qualification for deepfakes in evidently artistic, creative, satirical, fictional, or analogous works, so disclosure need not hamper enjoyment. Standard editing assistance is outside the provider marking obligation; consult the Commission’s guidelines on AI transparency obligations for scope and examples. The Commission’s Code of Practice is a voluntary compliance tool; the Article 50 obligations themselves are legal duties.
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U.S. advertising and testimonials
The FTC material addressed here does not establish a general U.S. requirement to label every AI-generated video. It does require advertising claims to be truthful, non-deceptive, and evidence-based. A visible AI label does not make a false or misleading claim acceptable.
For an ad, be especially careful not to present a synthetic avatar as a real customer or imply that the character personally used a product. The FTC says stock avatars generated by AI are not consumer reviews under the Consumer Reviews and Testimonials Rule’s definition, but their use may still function as a testimonial or be deceptive depending on presentation. A text disclosure in a video testimonial must stand out enough for viewers to notice it. See the FTC’s advertising guidance and Consumer Reviews and Testimonials Rule Q&A.
A practical pre-publish check
- Identify the material change. Note which scene, person, voice, or claim was generated or altered.
- Assess likely interpretation. Ask whether viewers could mistake it for real footage, a real event, or a genuine endorsement.
- Choose a noticeable placement. Put a plain-language notice at first exposure or close to the relevant scene, as applicable. Do not rely only on hidden metadata where a viewer-facing notice is required.
- Use the platform control. For YouTube, set the “AI use” option in YouTube Studio and check whether an automatic label appears.
- Check your role and audience. Determine whether you are subject to a platform rule, an EU deployer duty, an AI-provider obligation, U.S. advertising rules, or more than one of these.
Rules and upload flows can change. For a legally consequential publication, check the current official guidance for the platform and jurisdiction rather than assuming a label used elsewhere is sufficient.
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