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Knowledge base · AI in HR

Do we have to label job ads or recruitment images made with AI as AI content?

For text, the labelling duty applies only if you publish text to inform the public on matters of public interest, and it lapses if a human has reviewed or edited the text and someone holds editorial responsibility. If you use AI to make images, audio or video that could pass for real, a deepfake, you must disclose it. This has applied since 2 August 2026.

In force now (since 2 August 2026)Trusq editorial · checked against the official textLast verified:

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Text

Anyone who uses an AI system that generates or manipulates text published to inform the public on matters of public interest discloses that the text has been artificially generated or manipulated. That is not required if the text has undergone a process of human review or editorial control and a natural or legal person holds editorial responsibility [1]. Whether a job ad or a staff message falls under 'matters of public interest' depends on its content; if you have someone check every text and your organisation bears the responsibility, the exception applies.

Image, audio and video

A deepfake is AI-generated or manipulated image, audio or video content that resembles existing persons, objects, places or events and would falsely appear to be authentic [2]. Anyone who makes such content with AI, for example a recruitment video that imitates an existing person and falsely appears authentic, discloses that the content has been artificially generated or manipulated [3]. Not every synthetic character is a deepfake: that depends on the definition above [2].

When and how

The information is provided in a clear and distinguishable manner at the latest at the time of the first exposure [4]. The duties have applied since 2 August 2026 [5].

What the provider of the tool does

The machine-readable marking of generated text and images is a duty of the provider of the content generator, not of you as a deployer [6]. For generators that were already on the market before 2 August 2026, that marking duty applies at the latest from 2 December 2026 [7].

What Trusq bases this on

These released rules are in Trusq and are read again with every publication; if a rule changes, this page changes with it.

  • Disclosure of AI text on matters of public interest AI Act 50
  • Deepfake label AI Act 50
  • Marking of synthetic output AI Act 50
  • Who carries Art. 50(1) and (2) for this system AI Act 3, AI Act 50

Sources

  1. [1] AI Act Art. 50(4), second subparagraph (AI Act, Regulation (EU) 2024/1689). Deployers of a system that generates or manipulates text published to inform the public on matters of public interest disclose that the text has been artificially generated or manipulated, unless the text has undergone human review or editorial control and a natural or legal person holds editorial responsibility.
    Deployers of an AI system that generates or manipulates text which is published with the purpose of informing the public on matters of public interest shall disclose that the text has been artificially generated or manipulated. This obligation shall not apply where the use is authorised by law to detect, prevent, investigate or prosecute criminal offences or where the AI-generated content has undergone a process of human review or editorial control and where a natural or legal person holds editorial responsibility for the publication of the content.
    Source, retrieved on 2 October 2026.
  2. [2] AI Act Art. 3(60) (AI Act, Regulation (EU) 2024/1689). A deepfake is AI-generated or manipulated image, audio or video content that resembles existing persons, objects, places or events and would falsely appear to be authentic.
    ‘deep fake’ means AI-generated or manipulated image, audio or video content that resembles existing persons, objects, places, entities or events and would falsely appear to a person to be authentic or truthful;
    Source, retrieved on 2 October 2026.
  3. [3] AI Act Art. 50(4), first subparagraph (AI Act, Regulation (EU) 2024/1689). Deployers of a system that generates or manipulates image, audio or video content constituting a deepfake disclose that the content has been artificially generated or manipulated; for an evidently artistic, creative, satirical or fictional work, appropriate disclosure suffices.
    Deployers of an AI system that generates or manipulates image, audio or video content constituting a deep fake, shall disclose that the content has been artificially generated or manipulated. This obligation shall not apply where the use is authorised by law to detect, prevent, investigate or prosecute criminal offence. Where the content forms part of an evidently artistic, creative, satirical, fictional or analogous work or programme, the transparency obligations set out in this paragraph are limited to disclosure of the existence of such generated or manipulated content in an appropriate manner that does not hamper the display or enjoyment of the work.
    Source, retrieved on 2 October 2026.
  4. [4] AI Act Art. 50(5) (AI Act, Regulation (EU) 2024/1689). The information under Article 50 is provided in a clear and distinguishable manner at the latest at the time of the first interaction or exposure, and complies with the accessibility requirements.
    The information referred to in paragraphs 1 to 4 shall be provided to the natural persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure. The information shall conform to the applicable accessibility requirements.
    Source, retrieved on 2 October 2026.
  5. [5] AI Act Art. 113, second paragraph (AI Act, Regulation (EU) 2024/1689). The general date of application of the AI Act is 2 August 2026; the transparency duties of Article 50 fall under it.
    It shall apply from 2 August 2026.
    Source, retrieved on 2 October 2026.
  6. [6] AI Act Art. 50(2), first sentence (AI Act, Regulation (EU) 2024/1689). Providers of systems generating synthetic audio, image, video or text ensure that the output is marked in a machine-readable format as artificially generated or manipulated.
    Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, shall ensure that the outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated.
    Source, retrieved on 2 October 2026.
  7. [7] Regulation (EU) 2026/1744 Art. 1(39)(b) (adds AI Act Art. 111(4)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Providers of content generators that were on the market before 2 August 2026 must comply with the marking duty of Article 50(2) by 2 December 2026 at the latest.
    Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, that have been placed on the market before 2 August 2026 shall take the necessary steps in order to comply with Article 50(2) by 2 December 2026.
    Source, retrieved on 2 October 2026.

Related questions

Does our recruitment chatbot have to say that candidates are talking to AI?What do we, as an SME, have to arrange now if we use AI in HR?

Next step

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This page gives general information based on the text of the law. It is not legal advice for your situation.