EU Article 50 AI avatar video disclosure checklist for marketers
Tavus says EU Article 50 has required disclosure of AI likenesses since 2 August 2026. A checklist of what to label on an avatar clip, with the Sume fields.
Label every avatar video as AI-generated where you publish it, and keep documented consent for any real person's likeness. That is the safe default, and it matches what Tavus says in its October guide, How to create an AI clone from 2 minutes of video, read 2026-10-06: it states that EU Article 50 has required disclosure of AI-generated or manipulated likenesses since 2 August 2026, and that other jurisdictions have parallel rules. This post summarizes that claim, quotes no regulation text, and is not legal advice. Check the law that applies to you.
Checklist by clip type
Read the table by what the clip shows, not by which tool made it.
| Clip type | Consent needed | Disclosure | Sume input |
|---|---|---|---|
| Invented presenter from a prompt | No real person involved | Label as AI-generated | prompt or props |
| Presenter from a real photo | Documented consent from that person | Label as AI-generated | photo, public HTTPS image_url |
| Your own face as the avatar | Yours; keep it on file | Label as AI-generated | photo |
| Face swap onto a source video | Consent from the person whose face is used | Label as AI-generated | Face swap Beta, 4-15 s source |
Where to put the label
Wording should be plain. 'AI-generated presenter' is clearer than a hashtag, and it costs nothing to add.
- In the post caption or description, in plain words: 'AI-generated presenter'.
- On the landing page next to the embedded video.
- In the email body if the clip is sent to clients.
- In your own records, with the script and the consent form.
What Sume does not do
Sume does not add a visible label to your video and does not collect consent for you. The docs describe inline captions, which render the script, not a disclosure. Disclosure is your step, in the place you publish.
On YouTube, a separate help page covers its own synthetic-content label; read it too if you publish there.
A simple record
For each video, keep: the script, the avatar handle, who the likeness belongs to, the consent file, the publish date and where the label sits. Ten lines in a sheet is enough, and it is the first thing an auditor or a platform will ask for.
Sources
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