We read through what you’ve published and decide, asset by asset, which pieces the EU’s new AI rules require you to label.
Colophon is an AI content disclosure practice in Bristol. We label what needs it and keep a written record of every decision, so that if anyone asks, you can show your working. An asset, here, means any single ad, image, video, audio clip or post.
What changed on 2 August 2026
Article 50 of the EU AI Act, the European Union’s law on artificial intelligence, now applies to businesses that publish AI-made content. If an AI-made picture or recording shows a real-looking person, product, place or event, and someone could take it for real, the audience has to be told. AI-written text on matters of public interest is covered too.
The duty sits with whoever publishes. That might be you or your client, depending on what your contract says. It applies wherever you are based, as long as the content reaches people in the EU.
Fines reach €15 million or 3% of worldwide turnover, whichever is higher. We mention that once, here. Most of what we do is working out what you don’t have to label.
What most people have wrong
- “It only covers face-swaps.”
- The legal definition reaches well beyond faces, and product imagery gets caught more often than people expect.
- “The platform labels it for us.”
- Platform badges, and information hidden inside the file, don’t meet the requirement on their own. The duty stays with whoever publishes.
- “Anything with AI in it needs a label.”
- Most of it doesn’t. Working out what’s exempt usually takes a large share of a catalogue out of scope, as long as the reasoning is written down.
- “A label makes it legal.”
- It doesn’t. The European Commission’s Code of Practice, its detailed guidance on labelling, says consent and rights still apply.
- “We’re a UK company.”
- It follows the audience. A Bristol agency whose client’s ads run in Dublin is in scope.
What the work looks like
At the end of an audit you get a Disclosure Record: every asset, the decision on it, and the reasoning behind the decision. Here are two entries from a specimen record, with the reasoning blacked out. That part is the work.
| Where it ran | Facebook and Instagram, UK and Ireland |
|---|---|
| First live | 14 August 2026 |
| What the AI did | Showed the product with a feature it doesn’t have |
| Reasoning | |
| Decision | Label required |
| Label | AI, Modified. Top right, from first view. |
| Reviewed | 18 September 2026 |
| Where it ran | Website, all markets |
|---|---|
| First live | 22 August 2026 |
| What the AI did | Generated the setting behind a photographed product |
| Reasoning | |
| Decision | No label required |
| Label | None |
| Reviewed | 18 September 2026 |
The second entry matters as much as the first. A recorded no lets you keep publishing without second-guessing, and a lot of an audit is establishing which entries are noes.
Why not do it in-house?
You could. The rules are public, and a sharp designer could learn them. What takes the time is applying them to every asset in the same way, with reasoning that holds up when a client or a regulator asks to see it.
Then there’s the question of who checks. Asking the team that made the work to judge it is marking your own homework, and the Code expects regular users of AI to verify that their labels are applied properly. An outside record, dated and signed, covers that.
An audit of up to 100 assets is a fixed £2,500, and your team keeps making work while it happens.
Start with three links
Send links to three things you have running now. Anything public counts: ads, product pages, posts, trailers. We’ll send back one page with our view on each.
There’s no price in it. Usually at least one of the three comes back clean, and we’ll say so.
What it costs
Prices are fixed and published. The ten-asset Opening Review is £450. A full Article 50 Asset Audit starts at £1,500 for up to 40 assets, and monthly retainers start at £750. All services and prices.
Who it’s for
Mostly agencies of ten to forty people whose clients sell into Europe, and the in-house teams that brief them.
We also work with galleries, festivals, cinemas and venues. The Code of Practice has its own provisions for work on walls and screens, and hardly anyone in the sector has read them yet.
If you have in-house counsel and want a legal opinion, you need a solicitor. We’re glad to work alongside one.
Who we are
Colophon is a team based in Bristol. Our founder, Ridwanul (Ray) Kabir, has researched generative AI since 2020.
The law itself is short. Most of the work lies in knowing how a campaign actually gets made: who generated which file, and where it ended up. We answer that by reading the primary documents and going through the assets one at a time.
We sit between the lawyer who writes the opinion and the software that marks the file, doing the asset-by-asset work in the middle.
We’re not lawyers, and Colophon doesn’t give legal advice. When a case is genuinely unclear, we write the question down properly and pass it to your solicitor.
Colophon is a member of the Bristol Creative Co.