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Labeling AI-generated or modified photos — frequently asked questions

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Labeling AI-generated or modified photos — frequently asked questions

On August 2, the EU's Artificial Intelligence Act (AI Act) will come into force. It will introduce new rules for the transparency of AI-generated content online. To help you adapt to these new legal requirements, we will soon provide you with a beta version of a tool to label AI photos in your offers.

This article email is for informational purposes only. We want to give you a broader context of the upcoming changes in the law. This content does not constitute legal advice, a legal opinion, or an official interpretation of regulations. As Allegro, we do not assume legal responsibility for the decisions and actions you take based on this email. This information may become outdated due to the dynamic development of regulations and case law. Every seller should independently ensure a professional legal interpretation of the provisions of the Artificial Intelligence Act (AI Act) and adapt their operations to the applicable requirements.

Legal basis: Regulation (EU) 2024/1689 of the European Parliament and of the Council.

Under the regulations, if you publish a photo generated or modified using artificial intelligence in a manner specified by the AI Act, you must inform recipients about it — so that they can tell whether the image or video is real after seeing it for the first time.

The new law does not ban the use of AI — it only imposes a transparency requirement, meaning you must label such content in specific situations

Which photos may be subject to the new requirements

These requirements apply to images generated or modified by AI that might appear authentic (so-called deepfakes). These may include, for example:

  • photos generated from scratch — for example, when a product does not exist yet because it is made-to-order.
  • photos of a real product with an AI-generated background
  • virtual models — AI-generated characters presenting the product.

What it means for you

You are responsible for what you display in your offer. Assessing the nature of the photo and deciding whether and how to label it is your responsibility. We want to help you comply with the new regulations. By August 2 at the latest, you will be able to use a new option to label your AI content. The label will be available when you add photos:

  • to the Allegro Product Catalog
  • in the offer listing form
  • through a file
  • in the API.

If you use this option, an AI label will automatically appear on the photo as a watermark. You will see a preview before adding it.

Check the answers to the most frequently asked questions

This obligation only applies to photos that meet the definition of a deepfake — meaning generated or manipulated content that may appear authentic but is actually created by AI.

Yes. From December 2, 2026, AI tool providers will be required to add metadata about AI use to files. We are considering utilizing it in the future. However, you bear sole responsibility for properly labeling your photos — as Allegro, we do not automatically verify every photo.

As a seller, you are responsible for your offers. It is highly recommended to ask your suppliers whether the materials they provide have been generated or modified using AI.

Yes. The AI Act includes financial penalties for a lack of transparency. These penalties can be high, so make sure to implement correct labeling starting now.

First, we will only enable labeling newly-added photos. In the future, we might extend this to photos added before August 2, 2026.

We constantly monitor the market and react to sellers’ feedback. This is how we improve Allegro. We are starting with photos, as that is what buyers pay the most attention to. Regardless of the features we offer, analyze the regulations yourself and decide what you need to label in your offers.

We suggest using the beta version of our AI content labeling tool, which we will make available soon.

However, if you believe that our label does not meet your legal obligations for a specific photo, you can apply your own AI-use mark directly onto the image.

Once you save the photo, you will no longer be able to change its declaration. If you do not select anything, we will label your photo with a watermark.

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