[Feature Request] Marking of AI Images in the EU

Hey Realmac team,

I just came along with a new EU regulation

“labeling requirement for AI-generated or significantly manipulated images, provided they appear authentic and there is a risk of misleading the viewer.”

In short form it means that an AI image has to be marked as “AI Content” on all websites. The regulation is already in place since 2. August 2026. I don’t want to discuss the merits or flaws of such a regulation here, but this is something we, as website operators in the EU, must take into account. And to prevent that we are getting mail from dubious lawyers we should take that regulation serious.

We all can now of course start to manually mark all our AI pictures and publish them with a batch or so. But it would be good if we have a support within Elements.

What about a possibility to add a checkbox in the resource info tab to mark it as AI content.

And then a possibility in all image related components to publish a batch or so on the image when the checkbox is set.

The intention here is to raise the awareness that such a regulation exists and is already in place (I personally was not aware) and look for solutions.

Not for everything, though:

What exactly requires labelling
The phrasing “appear authentic … risk of misleading” refers to Art. 50(4) of the AI Act (deepfake obligation for deployers) — not every AI image:
• Required: AI-generated or -manipulated images that resemble real people, places, objects, entities, or events and could falsely appear authentic (e.g. photorealistic practice/office photos, “real-looking” team photos, stock-photo replacements from Midjourney/DALL·E)

Not required: obviously artificial illustrations, abstract graphics, clearly recognisable cartoons, decorative patterns.

• Important: For images there is no editorial exception — unlike for text

A checkbox would be nice, we just have to make sure any marking is also WCAG compatible, as this is also a legal requirement. Good would be a marker over the image, which only appears when a checkbox is checked - but this will be a problem for Gallery with a remote folder. In this case we would need a certain word or phrase in the title, so Elements can then add this marker.

I don’t understand why? What is the purpose?

Most of my Trumpet Blog are AI. Wasn’t going to spend 4 hours getting the perfect picture of trumpet mutes…

To me - this seems silly…

I’m sure there are edge cases of real concern - but a blanket labeling seems extreme - to me

Since you have asked for the feature I am assuming a blanket website disclaimer is not acceptable?

We’re not going to process images and watermark them, we’ll leave that up to the user before they import them.

We could flag them in code, but I’m wondering if there’s a standard for that yet? if not, what exactly do you want Elements to do?

I use Realmac Squash to watermark photos. Easy and fast - Powerful Batch Photo Editor for Mac - Squash

First, the good news for everyone outside the EU: this doesn’t apply to you. Grab some popcorn and enjoy the discussion :slight_smile:

Same as in my first post: a checkbox in the Resource Info tab, and an option in the image components to output a small badge when it’s set. No image processing, no watermarking pipeline on your side. But in the end I’ll leave the how entirely to you - you know best what’s feasible in Elements.

Yes, since last month. The Commission published its final Article 50 guidelines on 20 July 2026, along with a Code of Practice and an official EU icon set (SVG and PNG, free to use, no attribution required). The placement rules are spelled out too: perceivable at first exposure, not hidden behind overlays, alt/ARIA text where possible. Embedding into the file is preferred, but a UI overlay is explicitly accepted as an equivalent - which is the practical route anyway, since a burned-in watermark is unreadable at mobile breakpoints.

One clarification to my own opening post: it is not a blanket “label every AI image” rule. It targets AI content that resembles real people, objects, places or events and could pass as authentic, with a lighter regime for obviously artistic or fictional work - the test is whether the image could be mistaken for a real photograph, not how important the subject is

Quick facts: Quick Facts: Transparency rules for AI systems | Shaping Europe’s digital future
Icons and placement rules: EU Icons for labelling AI-generated content | Shaping Europe’s digital future

As I wrote at the start, my main goal here was awareness - I only came across this by accident myself. I’m not a lawyer, and for the ~25 AI images on my preview pages I can handle it manually, so I’m not really asking for myself. But a fair number of people here build sites for EU clients, and warning letters from law firms will probably arrive long before any regulator does. If the answer is “not an Elements problem”, that’s fine too - I’d just rather know it now than later.

This is how I do it:

The process comes down to four steps:

  1. One-time linking — a JavaScript file is loaded via the project’s Resources folder and linked to every page through the Site Template.
  2. Marking individual images — an image that has been AI-generated or AI-edited is given a recognisable CSS class via the Image component’s Inspector.
  3. Marking images inside a gallery — since a gallery has no per-photo setting, marking there happens through a fixed addition to the filename before uploading.
  4. Automatic display — when the page loads, the script recognises the marked images and adds a visible label to each, both visually and in the alternative text for screen readers.

ai-content-labeling-guide.pdf (196,4 KB)

ai-label.js.md (1,9 KB)

Wow that’s a little extreme… it’s nice but a lot of extra work…

Seems like just naming the file ‘ai’ would be best - to me

Perhaps put ”Made with AI” in the Alt tag and ”Made by ChatGPT AI for …” in the Author tag.

The good old EU do have long arms however -

Starting September 27, 2026, a new EU law on environmental claims will affect any property listing that can be viewed or booked by travelers in the EU—even if the property itself is located outside the EU.

Under the new law, environmental and sustainability claims shown to EU travelers will be subject to stricter requirements. If you display an environmental or sustainability claim to EU consumers, it must be substantiated by clear, verifiable evidence or be based on a certification scheme that meets the criteria of the EU Empowering Consumers for the Green Transition Directive (ECGT).

Not a long stretch to imagine this EU ruling on marking of AI images will eventually spread to all sites visible in the EU.

I for one do not want to be conned into purchasing something based on an AI generated image whether it is a product, a holiday, a wife etc etc. False advertising at its very core.

Thanks @CyberFredje, I’ll take a closer look at that. Looks like a workable route with little effort – and it also shows that this doesn’t have to be complicated.

Both would be a nice addition, but as I read the rules neither is enough on its own – happy to be corrected by anyone with deeper knowledge. The disclosure has to be perceivable to the visitor at first sight, and a filename never is. The alt tag actually does appear in the EU guidance, but as an accessibility addition on top of the visible label, not as a replacement for it.

There is a second layer that works roughly the way you describe – machine-readable marking in the file metadata. But that one is the AI provider’s job (OpenAI, Midjourney and so on), not ours.

I wouldn’t put it quite that strictly myself, but I do lean the same way. We’re flooded with AI images these days that are simply fakes, and a lot of people can’t tell the difference. Good products deserve good photos – it also says something about how much a manufacturer cares.

I’m usually not a fan of EU (over)regulation, but this one I can actually get behind. That said, I hope @dan and the team find a way that also works for beginners and part-time web designers – marking a handful of images shouldn’t turn into a project of its own. Rules like this can be a pain in the a.., but I’d rather see it as a chance to make Elements a little better than as a threat.

Either way, good to see the topic getting some attention :grinning_face:

In that case, two check boxes to save time

EU Ai alt :white_check_mark: (Made with AI)
Show: Made with AI :white_check_mark:

This way you wouldn’t have to type in alt name it would fill it in

This way a tag line below the photo would be added

If there truly is no other way…

I reckon the horse has long since bolted. I don’t think it is any longer possible to believe that any image you look at or any video that you watch is not AI generated or AI edited. Not sure a watermark will make any difference.