We have been labelling since August 2. Not because anybody fined us, but because the rule came into force and turned out to be convenient: it says out loud exactly what we were doing anyway.
Fact
The facts: Article 50 of the EU AI Act came into force on August 2, 2026 and is the first part of the regulation affecting every business using AI rather than only those building AI systems. Paragraph 4 requires creators of image, audio or video content constituting a deepfake to disclose that it was artificially generated or manipulated. The definition covers content resembling existing or fictional but realistic persons, objects, places and events that would appear authentic. Per Szymon Sieniewicz, counsel at Addleshaw Goddard, realistic architectural visualisations are likely caught by it. The obligations also cover AI-modified product photos, chatbots on a homepage and AI-generated text on matters of public interest. The European Commission's Code of Practice on transparency recommends an icon reading AI generated or AI modified, and the Commission has published such icons for public use. Fines reach 15 million euro or 3 per cent of annual turnover.
The key sits in the definition. It does not ask whether the building exists. It asks whether the image looks real. So a visualisation of an unbuilt house with people strolling in front of it is caught, while a stylised model with obviously drawn figures stays outside.
The same yardstick, the lawyer said, awaits games with realistic cities. This is not a trap set for architects. It is a rule for anything that looks like a photograph.
The rule does not ask whether the building exists. It asks whether it looks real.
The Commission's icons are free and public. Adding them is ten minutes of work and costs less than the lightest fine. And to a client it reads as craft rather than paperwork.
Sources
Regulation (EU) 2024/1689 (AI Act), Article 50Dezeen - AI architectural renderings must be labelled under EU AI ActThe visual is generated code-art, no third-party images.