What is a deepfake under the EU AI Act?
The AI Act defines a deepfake (Article 3(60)) as 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 or truthful. From 2 August 2026, deployers of systems generating deepfakes must visibly disclose that the content has been artificially generated or manipulated: on top of the provider-side machine-readable marking duty under Article 50.
Key boundaries
- Broader than face-swaps: voice clones, staged “event” footage and photoreal renders of real places all qualify;
- Evidently artistic, creative, satirical or fictional works get a lighter regime: disclosure in a manner that does not spoil the work;
- Consent of the depicted person does not remove the labelling duty.
The Türkiye layer
Deepfakes of real persons also engage Turkish personality rights (TMK), KVKK (a face or voice is personal data) and the November 2025 draft criminal provisions on AI-generated content. See our deepfake liability guide.
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