AI-Generated and AI-Modified Image Disclosure

The AI Act is a European Union regulation governing the use of artificial intelligence.

While we do not prohibit the use of AI in the creation of product images, responsibility for determining whether a particular image requires AI disclosure rests with the Partner.

According to the European Commission's guidance, this obligation applies not only to depictions of people but also to realistic representations of objects that may be perceived as authentic by users. The regulations are intended to increase transparency, reduce the risk of misleading buyers, and strengthen trust in content created or substantially modified using AI technologies.

Who do the new requirements apply to?

From 2 August 2026, the requirements apply to providers of artificial intelligence systems as well as businesses that use such solutions in their products and services, including e-commerce platforms and marketplaces.

How can images be disclosed?

On the Modivo Marketplace, information about the use of AI can be provided in two ways:

1. Disclosure during product creation

When adding or editing a product, complete the parameter indicating whether AI was used to create or modify the image. This information will be stored and used when the offer is published.

Use the following parameters:

• AI Main Image – for the main product image

• AI Image 1-6 – for the remaining product images

2. Automatic metadata detection

If uploaded image files contain metadata indicating the use of AI, the system may automatically detect this information. In such cases, no additional action is required. We support metadata stored in the following standards:

• XMP
• EXIF
• IPTC
• C2PA

This information will be stored and applied during the publication of your offer. Select the appropriate parameter value depending on whether the image was generated or modified using AI.

Important: Apply the label to the specific image, not the entire product. This ensures that the information is correctly associated with the relevant image.

When do the requirements apply?

We are committed to building trust with buyers, which is why information about substantial AI involvement should be available from the very first interaction with the content.

As a general rule, the more an AI-generated or AI-modified image resembles an authentic photograph or real-world representation, the greater the need for clear disclosure.

We require disclosure if an image contains:

• An AI-generated model, figure, or face
• An AI-generated product
• An AI-generated interior or product environment
• An AI-generated product visualization or rendering
• Substantial AI-based modifications to a product, its surroundings, or a model that could potentially mislead buyers

Disclosure is particularly important when content may be perceived as an authentic representation of people or products. However, not every image adjustment or product customization needs to be disclosed.

Images do not require disclosure if AI was used solely for:

• Color correction or minor retouching
• Background removal
• Removal of dust, stains, or other product imperfections
• Straightening, cropping, or sharpening the image

FAQ

Can I use AI-generated or AI-modified images?

Yes. However, in certain cases, the use of AI must be disclosed in accordance with applicable transparency requirements.

What metadata can I use to label content?

You can use metadata stored in the XMP, EXIF, IPTC, and C2PA standards.

Does every edited image need to be disclosed?

No. Standard image editing activities, such as color correction, cropping, or background removal, do not require AI disclosure.

Does a fully AI-generated image need to be disclosed?

Yes. If an image has been generated using an AI tool, it is subject to transparency requirements and must be appropriately disclosed.

What happens if an image is not disclosed?

Partners are responsible for providing accurate information about their product images. Failure to comply with applicable AI transparency requirements may result in significant penalties under the AI Act.

Glossary

AI-generated

Content created by AI, such as an image, video, audio file, or text.

AI-modified

Existing content that has been significantly altered using AI, for example through modifications to a face, background, or other elements of an image.