What is synthetic content?
Synthetic content is audio, image, video or text that has been generated or significantly manipulated by an AI system rather than captured or authored conventionally. It is the object of the EU AI Act’s marking regime: under Article 50, providers of generative AI systems must ensure outputs are marked as artificially generated in a machine-readable format from 2 August 2026. Two subsets attract visible labelling on top of the technical mark: deepfakes, and AI-generated text published to inform the public on matters of public interest — unless the text has undergone human editorial review with a person or entity holding editorial responsibility.
Scope notes
- “Significantly manipulated” covers AI-edited real footage, not only fully generated media — a real video with one AI-altered element is in scope;
- Assistive uses — grammar fixes and standard editing that does not substantially alter the input — generally fall outside the marking duty;
- Marking versus labelling: marking is a provider duty at the point of generation; visible labelling is largely a deployer duty at the point of publication. Contracts along the chain should allocate both.
The legal dimension
The machine-readable mark is a technical design requirement, not a disclaimer: the provider has to build it into the output pipeline, and techniques such as AI watermarking and embedded metadata are the obvious candidates. The duty sits alongside Article 50’s transparency rules for chatbots and emotion recognition, and — for providers of general-purpose AI models — alongside the GPAI regime. Any product with a generation feature — marketing copy tools, avatar apps, game asset pipelines — needs a marking design before August 2026, including for outputs that users export and republish elsewhere.
Turkish context
Türkiye has no synthetic-content marking statute in force; KVKK and general provisions apply, so a deepfake of a real person is attacked through personality rights, personal data and unfair competition rather than a dedicated labelling rule. Turkish products serving EU users fall under Article 50 directly, and building the mark once, to the EU standard, is cheaper than running a separate EU-only pipeline.
Do: inventory every feature that generates or materially edits media, and decide per output type how the machine-readable mark and any visible label are applied. Don’t: assume the duty belongs to someone else because you fine-tune or resell — allocation happens in the contract, not by default.
Related guides: AI Act Readiness Checklist.
Sources. Regulation (EU) 2024/1689 (AI Act).