AI-Generated Content: What Do I Need to Label, and How?

As of August 2, 2026, providers of AI systems (e.g., OpenAI, Google, Microsoft) have been required to label certain AI-generated or AI-manipulated content in a machine-readable format, e.g., through metadata or watermarks (transparency requirement under Article 50 of the EU AI Regulation).

Operators and users must also clearly label such content as AI-generated, provided that certain disclosure requirements (see below) apply. The label should be accessible, for example, through an alternative image description.

Important: If the system being used already automatically applies an AI icon to the content, the labeling requirement is met only if the icon complies with legal requirements—that is, if it is, among other things, clearly recognizable, accessible, and unambiguous (see Guidelines on transparency obligations for providers and deployers of certain AI systems)

Disclosure Requirements

In particular , AI-generated images, audio, and videos that could appear deceptively real (so-called "deepfakes") must be labeled as such.

For AI-generated texts , the disclosure requirement does not apply across the board, but primarily when the text is published, informs the public about a topic of public interest, and there is no editorial oversight or assumption of responsibility.

If the texts are used only internally or in exercises, labeling is not required.

If a natural person assumes editorial responsibility for the AI-generated text, the labeling requirement is also waived.

Whether AI is used solely as a support tool— for example, to assist with drafting, grammar, spelling, or translation—or whether an AI-generated draft is substantially revised independently, disclosure is generally not required—provided that, in this case as well, editorial responsibility is assumed by a person.

Excerpts from "Recommendations for University Faculty on the Use of Artificial Intelligence," by Miriam Burfeind, Laura Fiegenbaum, Tom Hartmann, Janine Horn, Julius Hoyer, Jasmin de Nys, and Maren Stephan; CC-0 license; abridged and reworded by twillo

For more information, please visit the European Commission's website:

Disclosure Requirements on twillo

In addition to the statutory provisions mentioned above, Section 4(3) of the twillo Terms of Use also stipulates that materials created using AI or containing AI-generated content must be labeled as such.

There is a field in the metadata form where you can enter this information:

Open the menu options (three dots) for the item to which you want to add AI information. Select " Edit Info " from the drop-down menu to open the metadata dialog.

In the following window, click on the manage license tab and open the information about AI origin and usage drop-down menu.

Here you can indicate that your material was created using AI and which tool you used. You can also add information about whether you are providing the AI content unchanged or if it has been manually edited.