# Is your AI label accessible? Article 50(5) AI Act, the BFSG and screen readers

> What Article 50(5) of the AI Act and German accessibility law mean for an AI label on a product image: screen readers, contrast, zoom, keyboard, colour.

URL: https://easyaiactlabels.com/en/guides/accessible-ai-label/

[Guides](/en/guides/) /Practice

# Is your AI label accessible? Article 50(5) AI Act, the BFSG and screen readers

Last updated: 4 October 2026 Responsible: Martin Jäger Created with AI 21 min read

Short answer

Article 50(5) of the AI Act requires the disclosure of a deep fake to be clear and distinguishable and to conform to “the applicable accessibility requirements”; Article 50 sets no requirements of its own but refers to the rules that already apply to an offering (guidelines, para. 144). For online stores selling to consumers, these are the Barrierefreiheitsstärkungsgesetz (BFSG) in Germany since 28 June 2025 and the Barrierefreiheitsgesetz (BaFG) in Austria, both with an exemption for microenterprises; Switzerland has no comparable technical requirements for private stores. In practice this means a label with a text alternative for screen readers, good contrast, no reliance on colour alone, no animation and legible on a phone, as of 1 October 2026.

**Research as of 1 October 2026.** An AI label does not only have to be visible. Article 50(5) of the AI Act (Regulation (EU) 2024/1689) also requires the disclosure to conform to “the applicable accessibility requirements”. This guide explains which rules these are for your store in Germany, Austria and Switzerland, what they mean for a label on a product image and how to check your label yourself. Whether an image needs a label at all is covered in [Which images in your store need an AI label?](/en/guides/which-images-need-a-label/); the variants and placement of the EU icons are covered in [The EU icons for AI images](/en/guides/eu-icons-ai-images/). For what a correct label looks like, see these [AI generated label examples](/en/guides/ai-generated-label-examples/).

## What does Article 50(5) AI Act require?

Article 50(5) has two sentences:

> “The information referred to in paragraphs 1 to 4 shall be provided to the natural persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure. The information shall conform to the applicable accessibility requirements.”

The first sentence governs when and how clearly the label has to appear. The second refers to accessibility rules without naming them. The Digital Omnibus (Regulation (EU) 2026/1744) changes nothing here; in Article 50 it only replaces paragraph 7 (Article 1 point 20). A consolidated version of the AI Act could not be retrieved on 1 October 2026.

The recitals say little on the subject. Recital 132, on chatbots and emotion recognition, ends with the sentence: “Such information and notifications should be provided in accessible formats for persons with disabilities.” Recital 134, on deep fakes, does not mention accessibility.

The Commission guidelines on Article 50 (Annex to C(2026) 5054 final of 20 July 2026) are more explicit:

-   **Para. 142, what “clear” means:** information is clear where it is “noticeable, easy to understand by and accessible for the natural person concerned (including persons with disabilities)”. It must also be understood by specific groups, “such as children or persons with disabilities when they are part of the audience foreseeably exposed to the content”.
-   **Para. 144, which rules apply:** providers and deployers must be aware of the applicable accessibility requirements, for example under Directives (EU) 2016/2102 and (EU) 2019/882, and “assess whether their product, service or content needs to comply with those rules”. If so, the information under Article 50 has to follow those rules too. And: “Article 50 AI Act does not impose distinct or additional accessibility requirements.”

The Bundesnetzagentur, Germany’s market surveillance authority for the AI Act, summarises this in the same way in its summary of the guidelines: actors check whether their offering falls under these directives and adapt the information accordingly, and Article 50 does not create any additional, separate accessibility requirements (our translation).

This results in two layers. The split is this guide’s own reading:

1.  **The accessibility law your store is subject to.** In Germany that is the BFSG for many stores, in Austria the BaFG. Its requirements then also apply to the label, because the label is part of your website.
2.  **The “clear” standard.** Even without an accessibility law, the disclosure has to be perceivable and understandable under para. 142 for the people who see the image, including persons with disabilities where they are part of the foreseeable audience. For an online store selling to consumers, there is much to suggest they are. How far this standard reaches technically, the guidelines do not say.

Under para. 5 the guidelines are non-binding; only the Court of Justice of the European Union can give an authoritative interpretation of the AI Act.

## Does the BFSG apply to your store?

The German Barrierefreiheitsstärkungsgesetz (BFSG, Accessibility Strengthening Act) implements Directive (EU) 2019/882. Under Section 1(3) no. 5 it applies to e-commerce services (“Dienstleistungen im elektronischen Geschäftsverkehr”) provided to consumers after 28 June 2025. Section 2 no. 26 defines them as digital services offered via websites and mobile applications and provided electronically at the individual request of a consumer with a view to concluding a consumer contract (our translation). An online store selling to consumers is covered.

Question

Answer under the BFSG and BFSGV

Provision

Do you sell to consumers?

Only then does the Act apply. A store that sells exclusively to businesses concludes no consumer contracts (our own reading)

Section 1(3), Section 2 no. 26 BFSG

Are you a microenterprise?

Then the obligation in Section 3(1) does not apply to your service

Section 3(3), Section 2 no. 17 BFSG

What does accessible mean?

findable, accessible and usable by persons with disabilities in the usual way, without particular difficulty and in principle without outside help (our translation)

Section 3(1), second sentence, BFSG

What applies to the website?

It must be designed to be perceivable, operable, understandable and robust in a consistent and appropriate manner (our translation)

Section 12 no. 3 BFSGV

Who monitors?

the joint market surveillance authority of the German federal states (MLBF) in Magdeburg

Bundesfachstelle Barrierefreiheit; MLBF

**Microenterprises.** Under Section 2 no. 17 BFSG, a microenterprise employs fewer than ten persons and has either an annual turnover of no more than EUR 2 million or an annual balance sheet total of no more than EUR 2 million. The exemption in Section 3(3) only covers microenterprises that offer or provide services; it derives from Article 4(5) of the Directive: “Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.” The MLBF explains that employees are counted in annual work units, linked enterprises have to be included depending on the type of link, and the classification only changes once the thresholds are exceeded or undershot in two consecutive financial years.

**Standards.** Under Section 4 BFSG, a service is presumed to meet the requirements if it conforms to harmonised standards whose references have been published in the Official Journal of the European Union. No such references for Directive (EU) 2019/882 could be found on 1 October 2026 (search of the Official Journal data). The German Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit) writes that, as long as the harmonised European standards envisaged in standardisation request M/587 have not been published and announced in the Official Journal, the current EN 301 549 and other recognised standards and guidelines, in particular the Web Content Accessibility Guidelines (WCAG), serve as the key reference for implementing the BFSG in practice (our translation). For web pages, clause 9 of EN 301 549 V3.2.1 takes over the WCAG 2.1 success criteria of levels A and AA.

**Monitoring.** According to the Bundesfachstelle, consumer complaints under the BFSG are handled by the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), a public-law institution based in Magdeburg. It also carries out random checks without specific cause (Section 28(2) BFSG), and consumers and recognised associations can apply for proceedings (Section 32). If the authority finds a deficiency, it asks for it to be remedied within a reasonable period (Section 29(1)). Anyone offering a service that does not meet the requirements commits an administrative offence under Section 37(1) no. 8; the fine can be up to EUR 100,000 under Section 37(2).

The AI labelling itself is monitored by a different body, in Germany the Bundesnetzagentur ([Who enforces the AI labelling obligation?](/en/guides/enforcement-and-violations/)). No statement by the MLBF or the Bundesnetzagentur specifically on the accessibility of AI labels could be found on 1 October 2026.

**The label is part of it.** The BFSG does not mention AI labels. On the most natural reading, a label that you or an app place over a product image on your behalf is part of your website and not third-party content excluded by Section 1(4) no. 4. That exclusion only covers content that the economic operator neither funds nor develops and that is not subject to its control.

## What applies in Austria?

Austria implements Directive (EU) 2019/882 with the Barrierefreiheitsgesetz (BaFG, Accessibility Act, BGBl. I No. 76/2023). Under Section 2(2) no. 6 it applies to e-commerce services provided to consumers after 28 June 2025. Section 3 no. 27 defines them as distance services provided electronically at the individual request of a consumer with a view to concluding a consumer contract via websites and mobile services (our translation).

-   **Requirements:** services have to meet the requirements in Annex 1, sections 3 and 4 (Section 4(3)). Websites have to be perceivable, operable, understandable and robust in a coherent and appropriate manner (Annex 1, section 3(c)).
-   **Standards:** conformity with harmonised standards whose references are published in the Official Journal gives rise to a presumption that the requirements are met (Section 5(1)).
-   **Microenterprises:** microenterprises offering or providing services are exempt from the accessibility requirements under Section 4(3) and from all obligations connected with meeting them (Section 6(1)). The thresholds are set out in Section 3 no. 19.
-   **Monitoring:** the Federal Office for Social Affairs and Disability (Sozialministeriumservice), Section 21.

For AI labelling itself, Austria had no market surveillance authority as of 30 September 2026 ([Labelling AI images in Austria](/en/guides/ai-images-labelling-austria/)).

## What applies in Switzerland?

For a store established in Switzerland, Article 50 AI Act applies to the AI images it uses in the EU, for instance because it sells to EU customers ([Labelling AI images in Switzerland](/en/guides/ai-images-labelling-switzerland/)). For those images, paragraph 5 also applies with its reference to “applicable” accessibility requirements. Which requirements those are for a Swiss provider, neither the Regulation nor the guidelines say.

Swiss law itself has no technical accessibility requirements for private online stores like the BFSG or the BaFG:

-   **Prohibition of discrimination:** private parties offering services to the public must not discriminate against persons with disabilities on the grounds of their disability (Article 6 BehiG, our translation). Under Article 2(d) of the Disability Discrimination Ordinance, discrimination means treating persons with disabilities in a particularly blatant, different and disadvantageous way with the aim or effect of degrading or excluding them (our translation).
-   **Consequence:** anyone who suffers discrimination can apply to a court for compensation (Article 8(3) BehiG), of no more than CHF 5,000 (Article 11(2)).
-   **Online services:** the duty to make internet services accessible to persons with visual impairments without additional difficulty applies to the authorities under Article 14(2) BehiG.

An amendment has been proposed. Under the Federal Council’s draft (BBl 2025 301), private parties offering services to the public would have to take reasonable accommodations to prevent, reduce or remove disadvantages connected with disabilities (our translation). It was not in force on 1 October 2026; the version of the BehiG in force on Fedlex is that of 1 July 2020.

## What does this mean for the label on a product image?

The following overview applies the WCAG success criteria, to which EN 301 549 and the Bundesfachstelle refer, to a label on a product image. The criteria read the same in WCAG 2.1 and 2.2 unless stated otherwise; quotations are taken verbatim from the W3C Recommendation. The right-hand column is our own reading.

Topic

Benchmark

On the label

Screen readers

WCAG 1.1.1 (level A); Commission page: alt text or ARIA labels; code of practice Measure 1.1

a text alternative such as “AI generated” on the label or in the image’s alt text

Contrast

WCAG 1.4.3 and 1.4.11 (AA); code of practice Sub-measure 1.2.1(d)

a solid area behind the lettering, an outline against the photo

Size, zoom, phones

WCAG 1.4.4 and 1.4.10 (AA); Commission page: clearly visible size

grows with the image, stays sharp when zoomed, does not cover the product on a phone

Keyboard and focus

WCAG 2.1.1 (A), 2.4.7 (AA), 4.1.2 (A); 2.4.11 and 2.5.8 (AA, WCAG 2.2 only)

a plain label takes no focus; a clickable label is keyboard operable

Motion

WCAG 2.2.2 and 2.3.1 (A); code of practice Sub-measure 1.2.1(b)

static, no blinking, no fading out

Colour

WCAG 1.4.1 (A); code of practice Measure 1.1

the word carries the message, not the colour

Language

WCAG 3.1.2 (AA); Commission page: plain language

a text alternative in the language of the page

No user action

code of practice Sub-measure 1.2.1(a); guidelines, para. 117

visible without hover, click or tap

### What does a screen reader read out?

A screen reader reads text, not pixels. WCAG 1.1.1 requires: “All non-text content that is presented to the user has a text alternative that serves the equivalent purpose”. A label that consists only of a graphic, whether burned into the file or shown as an overlay without a text alternative, does not reach a blind visitor. The Commission page on the EU icons therefore recommends making the icon readable by assistive technologies “if possible” using “alt text or ARIA labels”. The code of practice requires its signatories to ensure “screen-reader compatibility” and the detectability of the label by assistive technologies (Measure 1.1).

There are two ways to do this:

Approach

Example

Strength

Limitation

Text alternative on the overlay

`<span role="img" aria-label="AI generated">` over the image

independent of the alt text, one place for all images

only in the store; a downloaded image does not carry it

Note in the alt text of the product image

`alt="AI generated: linen dress in sand, front view"`

also covers a burned-in label, needs no script

has to be maintained per image and per language; Shopify treats alt text as a translatable field, and a translation without the note drops it in that language; the theme has to output the alt text wherever the image appears, which older theme versions do not always do

An example of the last limitation: Shopify’s Dawn theme has only output the alt text of the collection banner and collection cards since a fix from February 2024 (change 3262); older copies of the theme that were never updated do not show it there.

What else matters, in our own reading:

-   **Do not silence it.** The label is information, not decoration; the WCAG 1.1.1 exception for “pure decoration” does not fit. An overlay with `aria-hidden="true"` or a label graphic with an empty `alt=""` is only acceptable if the alt text of the product image carries the note.
-   **One route is enough.** If both the overlay and the alt text carry the note, it is read out twice. Pick one main route.
-   **Plain words.** For accompanying text, the Commission page recommends “plain language” without jargon and without abbreviations other than “AI”. “AI generated” or “Modified with AI” is understood by everyone; “synthetic content” or a reference to metadata is not.
-   **Language.** Under WCAG 3.1.2, the human language of each passage or phrase has to be programmatically determinable, with exceptions such as technical terms. If a German store page carries an English text alternative such as “AI generated”, mark it up with `lang="en"` or write it in German straight away. The visible EU icon may stay in English; the code of practice expressly provides for the acronym “AI”.
-   **No tooltip instead.** A note that only appears on mouse-over does not replace the visible label; under the code of practice, the disclosure has to be recognisable without user interaction (Sub-measure 1.2.1(a)).
-   **Images outside the store.** The same applies to image versions with a burned-in label in ads or on marketplaces: where the channel allows an image description, the note belongs there too ([AI images on marketplaces and in ads](/en/guides/ai-images-marketplaces-ads/)).

### How much contrast does the label need?

WCAG 1.4.3 requires a contrast ratio of at least 4.5:1 for text and 3:1 for large text (“at least 18 point or 14 point bold”). WCAG 1.4.11 requires 3:1 against adjacent colours for graphical objects needed to understand the content. The code of practice names “high contrast icons or equivalent labels” (Measure 1.1) and a label that will “remain visible against any background” (Sub-measure 1.2.1(d)).

Over a photo, the background cannot be planned. In our own reading, this means:

-   **Lettering on its own area.** The black EU icon is a black pill with white lettering; white on black reaches the highest possible ratio of 21:1, whatever photo lies behind it. The white variant with near-black lettering is also well above 4.5:1.
-   **An outline against the photo.** On a dark product image a black pill disappears, on a light one a white pill does. A light edge or shadow helps, or you choose the variant that suits the image.
-   **Care with the half-transparent variants.** The Commission also offers both colours in half-transparent versions; in the official files, the area is half-transparent while the lettering stays opaque. On busy photos, the contrast of the lettering can still drop. Check it on the actual image; the free [AI Label Generator](/en/ai-label-generator/) shows all four colour variants on your own image.

### Size, zoom and phones

The Commission page recommends a “clearly visible size”. Neither the code of practice nor the Commission page sets a minimum size in pixels or per cent. Two WCAG benchmarks apply here: text can be resized to double its size without assistive technology and without loss of content or functionality (1.4.4), and content remains fully usable at a width of 320 CSS pixels without scrolling in two dimensions (1.4.10).

For the label, in our own reading, this means:

-   **Size it for legibility**, with a lower limit so that it stays legible on small thumbnails and an upper limit so that it does not cover the product on a phone.
-   **Use a vector graphic.** An SVG stays sharp when zoomed; a small PNG becomes blurred.
-   **Leave space.** On small screens, the sale badge, wishlist button and label move closer together. The code of practice requires sufficient spacing to other overlay elements (Sub-measure 1.2.1(d)); choose the corner accordingly.
-   **No hover.** Phones have no mouse-over. If a collection shows an AI image only on hover, the label has to appear with that image, and on a phone the disclosure must not depend on a gesture.

### Does the label have to be reachable by keyboard?

A plain label is not a control. WCAG 2.1.1 requires that “all functionality of the content” is operable through a keyboard; a label without a function therefore does not need to be in the tab order. If you put it there anyway, keyboard users land on an element that does nothing (our own reading).

It is different if the label is clickable, for example to open a second layer with an explanation, as the code of practice encourages (Measure 1.1(b)):

-   operable by keyboard (2.1.1), with a visible focus (2.4.7), and with a programmatically determinable name and role (4.1.2);
-   an explanation that opens can be dismissed without moving the pointer or focus, stays in place when hovered and does not disappear on its own (1.4.13);
-   the target measures at least 24 by 24 CSS pixels or has enough spacing (2.5.8, WCAG 2.2 only);
-   according to the Commission page, the icon should make clear that further information is available, and the second layer “shall be navigable using assistive technologies”.

In both cases, the overlay must not block the image’s own function, such as the click to enlarge it, and under WCAG 2.2 (2.4.11) it must not entirely hide the focus of other elements, such as a wishlist button in the same corner.

### May the label be animated?

The code of practice requires the label to remain visible at least long enough to be noticed under normal exposure conditions (Sub-measure 1.2.1(b)). The Commission page adds that if the disclosure appears for a limited time, it should “remain visible long enough to be read and understood by users with cognitive or processing difficulties”. WCAG 2.2.2 requires a way to pause, stop or hide moving or blinking information that starts automatically, lasts more than five seconds and is shown alongside other content. WCAG 2.3.1 rules out anything that flashes more than three times in any one second, unless the flashes are below certain thresholds.

The simplest option is a static label: on a still image it stays in place permanently, without blinking, pulsing or a delayed fade-in (our own reading). Then these questions do not arise at all.

### Why is colour alone not enough?

WCAG 1.4.1: “Color is not used as the only visual means of conveying information”. A green frame or a coloured dot as the only sign of AI origin does not reach people with colour vision deficiencies; the code of practice expressly mentions “end-users with colour vision deficiencies” (Measure 1.1). The guidelines, too, treat coloured frames, for chatbots, only as a complement to text (para. 37). The EU icon carries the message in the word. If you also distinguish AI GENERATED from AI MODIFIED by colour, the word still has to carry the difference.

## How do you check your label?

1.  **Turn on a screen reader**, such as VoiceOver on Mac and iPhone, TalkBack on Android or NVDA on Windows, and navigate over the image: do you hear “AI generated” or “AI modified”, and only once?
2.  **Look at the source code**: does the label have `role="img"` with an `aria-label`, or does the image’s alt text state the AI origin? Is there an `aria-hidden="true"` anywhere without a replacement?
3.  **Zoom to double size** (Ctrl or Cmd and plus): does the label stay sharp, legible and on the image?
4.  **Narrow view** in the browser’s developer tools, 320 CSS pixels wide: does the label cover the product, a discount note or the wishlist button?
5.  **Light and dark images**: is the label clearly visible on both? A contrast checker measures the ratio.
6.  **Greyscale** via the operating system’s colour filter: is the message still there without colour?
7.  **Tab key**: does the focus jump to a label without a function, or does the label hide another element’s focus outline?
8.  **Without mouse or tap**: is the label there at first glance, including for hover and variant images?
9.  **Every language**: in a multilingual store, check the alt texts and text alternatives for each language.

The Shopify app Easy AI Act Image Labels shows the label as an overlay with `role="img"` and a text alternative (`aria-label`) and leaves the alt texts of product images unchanged. The label sits below the theme’s buttons and text, and clicks pass through; you choose the corner.

## What is still open?

-   **How far “clear” reaches without an accessibility law:** para. 142 of the guidelines includes persons with disabilities in the “clear” standard, while para. 144 says Article 50 imposes no additional accessibility requirements. Whether a microenterprise outside the BFSG still owes a text alternative has not been decided; the guidelines are non-binding (para. 5). As a text alternative takes little effort, there is much to be said for adding it.
-   **No harmonised standard:** on 1 October 2026, the Official Journal contained no reference to a harmonised standard under Directive (EU) 2019/882. EN 301 549 and WCAG are a reference point, not a basis for the presumption under Section 4 BFSG. According to the Bundesfachstelle, the revised EN 301 549 will refer to WCAG 2.2.
-   **The EU icon as an image of text:** the official files draw the letters as vector shapes. WCAG 1.4.5 asks for real text rather than images of text where the technology can achieve the presentation, with exceptions, for example where a particular presentation is essential to the information; logotypes count as essential. Whether an official label falls under this has not been settled.
-   **Swiss stores with EU customers:** whether the BFSG or the BaFG covers a store established in Switzerland that sells to consumers in the EU is open. Section 2 no. 4 BFSG refers to services offered “on the Union market” (our translation); no statement by an authority on this could be found.
-   **Authority practice:** neither the MLBF nor the Bundesnetzagentur had commented specifically on the accessibility of AI labels by 1 October 2026.

## In short

Article 50(5) AI Act requires a clear label that conforms to the applicable accessibility requirements, without setting any of its own. Which requirements these are depends on your store: in Germany the BFSG for stores selling to consumers, in Austria the BaFG, both with an exemption for microenterprises; in Switzerland there are no comparable technical duties for private stores. In practice, every label needs a text alternative for screen readers, a solid area with good contrast, a word rather than a colour code, a presentation without animation and a size that stays legible on a phone without covering the product. The WCAG, to which EN 301 549 also refers, serve as the benchmark. For the full picture, see [EU AI Act Article 50](/en/guides/eu-ai-act-article-50/).

## Frequently asked questions

### Does my AI label have to be accessible?

Article 50(5), second sentence, of the AI Act requires the disclosure to conform to the applicable accessibility requirements. Article 50 sets no requirements of its own; the rules that already apply to your store govern, in Germany the BFSG for stores with consumer customers that are not microenterprises (guidelines, para. 144). Independently of that, the guidelines only regard information as clear if it is also perceivable and understandable for persons with disabilities (para. 142). A text alternative for screen readers therefore belongs with the label in practice.

### Is the alt text enough as a label?

No. Sighted visitors do not see the alt text, and the disclosure has to be perceivable without technical tools or dedicated actions (guidelines, para. 117). Conversely, a visible label without a text alternative does not reach a screen reader. You need both: the visible label and a text alternative, either as an aria-label on the label or as a note in the alt text of the product image.

### Does the BFSG also apply to small stores?

Not to microenterprises: a business with fewer than ten employees and an annual turnover or annual balance sheet total of no more than EUR 2 million is exempt, as a service provider, from the obligation in Section 3(1) BFSG (Section 3(3), Section 2 no. 17). The disclosure under Article 50(5) AI Act still has to be clear, and under the guidelines that includes persons with disabilities (para. 142). A text alternative on the label takes little effort.

### What contrast does the label need?

The WCAG, which EN 301 549 also refers to, serve as the benchmark: at least 4.5:1 for text, 3:1 for large text and for graphical elements needed to understand the content (WCAG 1.4.3 and 1.4.11). Over a photo, a solid area behind the lettering helps, such as the black pill of the EU icon with white lettering, plus a light outline against dark images. The code of practice asks for a label that remains visible against any background.

### Does the label have to be reachable by keyboard?

A plain label does not, as it is not a control. If it is clickable, for example to open an explanation, it has to be operable by keyboard, with a visible focus and a name (WCAG 2.1.1, 2.4.7, 4.1.2), and the explanation has to be navigable with assistive technologies (Commission page on the EU icons).

### What applies in Austria and Switzerland?

In Austria, the Barrierefreiheitsgesetz applies: online stores for consumers are covered, microenterprises providing services are exempt (Section 2(2) no. 6, Section 6(1) BaFG), and the Sozialministeriumservice is the competent authority (Section 21). Switzerland has no comparable technical requirements for private stores; the Disability Discrimination Act prohibits private parties offering services to the public from discriminating against persons with disabilities (Article 6 BehiG). If a Swiss store uses AI images in the EU, Article 50 AI Act, including paragraph 5, applies to them.

## Sources

1.  Regulation (EU) 2024/1689 (AI Act), CELEX 32024R1689, Article 50(5), recitals 132 and 134, Cellar resolver. [publications.europa.eu](http://publications.europa.eu/resource/celex/32024R1689) (accessed 1 October 2026)
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4.  Code of Practice on Transparency of AI-Generated Content (10 June 2026), Section 2, Commitment 1, Measure 1.1 and Sub-measure 1.2.1. [ec.europa.eu](https://ec.europa.eu/newsroom/dae/redirection/document/129555) (accessed 1 October 2026)
5.  European Commission, EU Icons for labelling AI-generated content, section “How to display the EU icons?” (last update 24 September 2026). [digital-strategy.ec.europa.eu](https://digital-strategy.ec.europa.eu/en/policies/eu-icons-labelling-ai-generated-content) (accessed 1 October 2026)
6.  Bundesnetzagentur, Transparenzpflichten: summary of the guidelines on Article 50, section 7 (in German). [bundesnetzagentur.de](https://www.bundesnetzagentur.de/DE/Fachthemen/Digitales/KI/4_Transparenzpflichten/Leitlinien/artikel.html) (accessed 1 October 2026)
7.  Directive (EU) 2019/882 on the accessibility requirements for products and services, CELEX 32019L0882, Article 4(5), Article 15, Cellar resolver. [publications.europa.eu](http://publications.europa.eu/resource/celex/32019L0882) (accessed 1 October 2026)
8.  Germany, Barrierefreiheitsstärkungsgesetz (BFSG), Sections 1 to 4, 14, 28, 29, 32, 37 (in German). [gesetze-im-internet.de](https://www.gesetze-im-internet.de/bfsg/) (accessed 1 October 2026)
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This article is general information, not legal advice. Whether an image needs a label is your decision; for your specific case, please ask a lawyer.

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