AI-generated images on a website: when must they be disclosed?
An AI-generated image must be disclosed if it gives the impression of being real about the company itself, its facility or its product. In Turkey, an explicit disclosure has been mandatory in two cases for consumer advertising since August 1, 2026; in the EU, the AI Act’s disclosure rule for generated images that appear real has applied since August 2, 2026. For a manufacturer selling to companies, the test is whether the image misleads about its own business.
Is using AI-generated images prohibited?
No. Neither Turkey’s advertising rules nor the EU AI Act prohibit generated images; both ask for this to be stated in certain cases. The boundary is what the image shows: a texture background or an illustration misleads no one, while an image that looks like the company’s facility or product can. For a manufacturer selling to companies, this boundary is drawn by the unfair competition provision of the Turkish Commercial Code: a false or misleading statement about one’s own business.
What has changed in Turkey since August 1, 2026?
Two provisions on artificial intelligence entered the Commercial Advertising Regulation, and both cover advertising aimed at consumers. Under the eighth paragraph of the new Article 18, if artificial intelligence or other software is used in a way that significantly affects the consumer’s economic behavior, or if digital characters indistinguishable from humans are featured, this is stated clearly, understandably and distinguishably. The twelfth paragraph of the new Article 27 prohibits advertising that gives the false impression that an AI-generated copy of a real person has experienced, used or recommended the product.
The rule needs a narrow reading: not every generated image falls under one of these two paragraphs. A generated image of a fabric swatch card is not in itself a use that significantly affects economic behavior, nor a digital character indistinguishable from humans. But if the image gives the impression of showing the product’s real color or texture, the general provisions of the misleading advertising ban still apply.
What is a misleading image?
The fifth paragraph of Article 7 of the Regulation says that an advertisement may not contain statements or images that can directly or indirectly mislead the consumer, and lists the subjects. Three items are closest to a manufacturer’s website: the structure, composition, production method, technical features, origin and environmental impact of the goods (a); the trade name, status and areas of authority of the company offering the goods (c); official recognition or approval, medals, awards, diplomas and similar documents (g). The rule measures not the words but the impression: one can mislead with an image alone, without writing a single sentence.
Apply this list to a generated image and the questions become clear: does the image show a texture, color or finish the product does not actually have; a production line that does not exist; the image of a certificate or award that was never received? If even one answer is “yes”, the image can mislead even if you say it was generated. A disclosure says the image is not real; it does not make what the image shows true.
What applies in the EU?
Article 50(4) of the AI Act: anyone using “deep fake” content discloses that it has been artificially generated or manipulated. Under the Act’s definition, a deep fake is 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. The rule has applied since August 2, 2026; the July 2026 amendment (2026/1744) did not touch this paragraph. For evidently artistic, creative or fictional works, the obligation is limited to disclosing in an appropriate manner that the content is generated.
For a Turkish manufacturer, the important detail is scope: the Act also covers deployers established in a third country if the output is used in the EU. So a generated image that appears to show your own facility on a site addressed to buyers in the EU can meet the elements of the definition. Not every generated image is a deep fake: the definition depends on resembling something that exists and appearing to be real.
When does a generated image instead of a facility photo mislead?
When it shows a production area that does not exist, or is not yours, as if it were yours. A buyer looks at a facility photo to make a decision about capacity, layout and machinery; a generated factory image bases that decision on information that is not real. For facility, machinery and team images, the safe route is a dated photo of your own facility; the details are in the factory and capacity page guide. Using another company’s facility photo is an even clearer problem than a generated image: a misleading statement about your own business.
What should be done with product, swatch card and texture images?
Say that the image is representative and what is real. On November 10, 2026, the website of a textile manufacturer client of ours did this in two places: on the home page and on the fabrics page, a paragraph next to the images saying, in substance, that the swatch card images and videos are representative and AI-generated and that a real sample is sent on request; and the same information in the alt text of 10 of the 22 images on the home page. The alt text of the 15 images on the fabrics page did not carry this information; a buyer using a screen reader could hear the disclosure there only from the paragraph. When the disclosure is in both places, it reaches both the reader who sees and the reader who listens.
What is written for which image?
| Image | Risk | What to write |
|---|---|---|
| Abstract texture, background, illustration | Does not mislead | No disclosure needed; a general note is enough for consistency |
| Product, swatch card, color sample | Impression of showing the real color or texture | Next to the image and in its alt text, “representative, generated with AI”; how to request a real sample |
| Facility, machinery, team | Showing a facility that does not exist or is not yours | Do not use; a dated photo of your own facility |
| Generated image of a real person | In consumer advertising, the impression that the person experienced or recommends the product is prohibited (Art. 27(12)); in the EU, a deep fake | Do not use |
| Digital character indistinguishable from humans | Explicit disclosure mandatory in consumer advertising (Art. 18(8)) | A clear, distinguishable disclosure next to the image |
What to do with which image
- ANo disclosure needed
- BClear disclosure next to the image
- CDo not use
How is the disclosure written?
Briefly, right next to the image and in the alt text, in the same words. Example phrases: “The image is representative and was generated with AI.” · “This image was created with AI; a real photo of the product is on the product page.” · “Color samples are representative; a real sample is sent on request.” The disclosure belongs not in the page footer or a separate legal text but where the image is; the reader should see it at the same time as the image.
How to test it: ask two questions for every image on your site: does this image show something that exists, and can the reader learn next to the image that it is not a real photo? If you answer “yes” to the first and “no” to the second, the disclosure is missing.
The information here is not legal advice; confirm which rule applies to you from official sources and consult a lawyer about your own situation.
Let’s go through the images on your site together with this table and write down, page by page, which ones need a disclosure and which need a real photo.
For a site that shows your certificates as a record buyers can verify, B2B website builds and measures the certificate page, the product scope and the path to a quote together.
FREQUENTLY ASKED QUESTIONS
Is it legal to use AI-generated images?
Yes, using them is not prohibited. In Turkey an explicit disclosure is required in two cases in consumer advertising, and in the EU for generated images that appear real; if you sell to companies, the image must not mislead about your business.
Is writing it in the alt text enough?
Alt text appears only to screen readers and when the image does not load. The disclosure should also be next to the image as visible text; when both are written in the same words, it reaches both the reader who sees and the reader who listens.
Does a real photo edited with AI also need a disclosure?
Yes, if the edit changes what the photo shows — adding a machine that does not exist, changing the color of the product. The EU AI Act’s definition covers manipulated images as well as generated ones. Corrections such as lighting and cropping that do not change what is shown are not covered.