Do I have to disclose that my product photos or ads are AI generated?

What do the Australian rules say about disclosing AI?

There is no AI-specific disclosure rule. Ad Standards said in May 2026 that there are currently no specific rules around AI-generated content in advertising, so the test is the Australian Consumer Law's: the ad must not mislead.

Ad Standards made the point when it released a Roy Morgan survey it commissioned, in which 64% of Australians said it should always be necessary to disclose when advertising contains AI-generated content. The rules may change, and shoppers already expect more than the law asks.

The legal side, including why a label does not rescue a misleading image, is covered in is it legal to use AI-generated images of my product in Australia and NZ? This page is general information, not legal advice.

What are the disclosure rules in New Zealand?

The Advertising Standards Authority treats AI like any other production method. Its guidance on generative AI says the codes are technology-neutral, so an ad made with AI must comply with the same rules and accurately reflect the product, and it does not ask for an AI label.

The ASA also asks advertisers using AI-generated images to watch for built-in bias and negative stereotypes, and to have checks in place across content creation and placement. Both points apply to generated people more than to product scenes.

Which platforms label AI ads or require a label?

Meta, Google and TikTok all have rules, and they differ. Meta and Google add labels themselves for ads made with their own AI tools, TikTok makes the advertiser declare AI content, and Google Shopping reads it from the image file.

Sources: Meta's newsroom (updated June 2026) and help centre; Google's ads announcement (July 2026) and merchant help; TikTok's advertising policies (April 2026).

Each of these labels describes how the ad was made. None of them says whether the product in the frame matches the one you ship, and that check stays with you.

Do I have to disclose AI if I sell to customers in Europe?

Possibly. Article 50 of the EU AI Act has applied since 2 August 2026, and it requires deployers of AI to disclose deepfakes, which the European Commission defines as content resembling existing persons, objects, places, entities or events that would falsely appear authentic or truthful.

The Commission's guidance on Article 50 does not mention product images or advertising, so whether a styled scene of a real product meets that test is not settled. If Europe is a real market for you, get advice and consider a clear disclosure on the listing.

Should I disclose AI imagery even when no rule requires it?

Consider it wherever a shopper could reasonably take the image for a photograph of a real place or person. A short, plain line in your FAQ or product description costs little and answers the question before anyone asks.

Something like "Our lifestyle scenes are made with AI from photos of the real product, which is shown exactly as it is" covers it. What a line cannot do is make up for an inaccurate product, and what you should never do is describe a generated frame as a studio shoot or a customer's home.