Which language does the AI label have to be in? The English EU icon or the local language

Research as of 1 October 2026. If you sell from one EU country into several others, you will want to know whether the English EU icon “AI GENERATED” is enough for customers in France, Poland or Italy. The answer sits on four levels, which this guide treats separately: the AI Act itself, the Commission guidelines and the Code of Practice, national language laws on consumer information, and practice. Which icons exist and where they sit on the image is covered in The EU icons for AI images; whether an image needs a label at all in Which images in your store need an AI label?. Examples of correct labels are shown in AI generated label examples.

What does the AI Act say about language?

Nothing explicit. Article 50(5) of the AI Act (Regulation (EU) 2024/1689) only requires the information to be provided “in a clear and distinguishable manner at the latest at the time of the first interaction or exposure” and to conform to accessibility requirements. Recital 134, which explains the deployers’ obligation, likewise only says that they “should also clearly and distinguishably disclose that the content has been artificially created or manipulated”.

Other provisions show that the regulation does address language where it wants to: providers of high-risk systems hand documents to authorities “in a language which can be easily understood by the authority” (Article 21(1)), and the EU declaration of conformity “shall be translated into a language that can be easily understood by the national competent authorities” (Article 47(2)). There is no such rule for Article 50.

On the most natural reading, the regulation does not displace national language laws. Article 50(6) is “without prejudice to other transparency obligations laid down in Union or national law for deployers of AI systems”, and the Code of Practice expressly assumes that national language laws apply alongside it (see below). The Digital Omnibus (Regulation (EU) 2026/1744) only amends paragraph 7 of Article 50 (Article 1 point 20) and adds no language rule. A consolidated version of the AI Act was not available on 1 October 2026.

What do the guidelines and the Code of Practice say?

The guidelines: what counts is whether the audience understands

The Commission guidelines on Article 50 (annex to C(2026) 5054 final of 20 July 2026) are non-binding; only the Court of Justice of the European Union can give an authoritative interpretation of the AI Act (para. 5).

• Para. 142: Information is clear where it is noticeable, “easy to understand by and accessible for the natural person concerned”. It must also be easily understood by the audience, including specific groups such as children or persons with disabilities where they are foreseeably part of it.
• Footnote 40 to para. 142: The only express language rule in the guidelines. Where children are part of the target audience, notifications should, among other things, be “presented in the official language(s) of the Member State the service is provided in”. The Bundesnetzagentur, the German market surveillance authority, renders this in its German summary as written in the official language of the country.
• Paras. 114 and 115: Whether an image falsely appears authentic depends, among other factors, on “the intended and reasonably foreseeable audience composition”. These paragraphs are not about language. But anyone who has to determine that audience anyway also knows which languages it speaks (our reading).

For stores whose images are also aimed at children, such as toys or children’s clothing, footnote 40 therefore points towards the local language; for everyone else, para. 142 means the label has to be easy to understand for the actual audience (our reading).

The Code of Practice: “AI” in English, with a proviso

The language rule is in Section 2 of the Code of Practice on Transparency of AI-generated Content of 10 June 2026, Measure 1.1(a). The main visual element of the icon or equivalent label is “the capitalised acronym ‘AI’ in the English language (e.g., an ‘AI’ icon), unless use of English is incompatible with applicable national laws on the use of languages in commercial or administrative matters in which case the acronym may be disclosed in the national language”.

Four further points matter for the language question:

• The word is open. Under point (b), signatories are only encouraged to supplement the acronym with text, for example “text indicating ‘modified’ or ‘generated’”. The Code sets no language for it.
• Audio has a language rule, images do not. For audio-only content, the spoken disclaimer should be “either in the same language as the content or in English”. There is no comparable rule for the word in a visual icon.
• The audience counts. When applying the design specifications, signatories consider the composition of the audience, expressly including differing “language proficiency”.
• Other laws remain. Signatories recognise that labelling does not exempt them “from other Union and Member States’ laws”; under objective (f) of Section 2, the Article 50 obligations “apply in parallel to, and do not affect, other legal obligations”, expressly including consumer protection.

The Code binds signatories only. For everyone else, it is the most detailed benchmark a label can be measured against; under Section 2, adherence does not constitute conclusive evidence that Article 50 is met.

The Commission’s icon page

The official icons exist only with English wording (details in The EU icons for AI images). The page says nothing about translations, language versions or whether the wording may be changed (page version of 24 September 2026, accessed 1 October 2026). Two statements still help:

• Basic icon with your own text. According to the Commission, the basic “AI” icon is meant for cases where AI was involved or “when a custom text label or interactive second layer is implemented”. Annex 1 of the Code says the same: the basic icon enables deployers to supplement it with “an alternative textual label”. Local-language text next to the basic icon is therefore built into the EU icon system (our reading).
• Accompanying text in plain language. Any accompanying label should use “plain language” and avoid jargon, confusing wording and “abbreviations other than ‘AI’”. Read strictly, the German “KI” or the French “IA” is another abbreviation. Spelling the text out, for example “image générée par intelligence artificielle” in French, follows this recommendation and avoids the abbreviation question (our reading).

Is a translated icon still the EU icon?

No, but it does not have to be. Besides the EU icon in Annex 1, the Code expressly allows “an equivalent icon or label” that complies with the design and placement specifications (Commitment 1). On the most natural reading, a label with “AI” and a translated word is such an equivalent label: it does not alter the Commission’s file but follows the same specifications, such as letters of equal height in the acronym, preserved proportions when resized, and a clear and accessible design (Measure 1.1(a) and (c)). The licence on the icon page allows free use without attribution; it says nothing about changes or translations. A translated label should therefore never be called “official”.

Which countries require their own language?

The Code refers to national laws “on the use of languages in commercial or administrative matters” without naming them. This guide checked France, Poland, Italy and Spain as well as Germany and Austria, each against the statutory text (accessed 1 October 2026). None of these provisions mentions AI labels. The right-hand column is therefore our reading; no statement by an authority and no court decision on the language of AI labels was found for any of these countries.

France: the Loi Toubon

Article 2 of Loi n° 94-665 of 4 August 1994 requires French “dans la désignation, l’offre, la présentation” of a good, product or service, that is in its designation, offer and presentation; the second paragraph extends this to “toute publicité écrite, parlée ou audiovisuelle”, all written, spoken or audiovisual advertising. Other languages are not banned: where statements are translated, the French version has to be “aussi lisible, audible ou intelligible”, as legible, audible or intelligible as the foreign-language one (Article 4, second paragraph). Légifrance blocks automated access; the wording of Article 2, first paragraph, has been cross-checked against the Ministry of Culture’s rendering.

The Circulaire of 19 March 1996, which explains how the law applies, describes the obligation as a “usage obligatoire, mais non exclusif”, a mandatory but not exclusive use of French. Translations need not be word for word (“la traduction peut ne pas être au mot à mot”), and the rules apply to goods marketed in France “quelle que soit l’origine de ceux-ci”, whatever their origin. It names no general exception for established English terms in advertising or offers; exceptions exist, for example, for engraved, moulded or woven inscriptions on goods (“on/off”, “made in”, “copyright”) and for the names of typical products such as “pizza” or “jeans”. Under the Circulaire, breaches of Article 2 are fourth-class petty offences (contraventions, Décret n° 95-240).

The Ministry of Culture states on its page on the Loi Toubon that the obligation applies to goods and services marketed in France, “y compris lorsqu’ils sont importés ou proposés sur des sites et plateformes de vente en ligne”, including when offered on online sales sites and platforms, and that the DGCCRF, the French consumer protection authority, enforces Article 2 “y compris dans le commerce électronique”. At the same time, it notes that EU law only allows a national-language requirement for mandatory particulars, proportionately and provided that “une autre langue facilement compréhensible”, another easily understood language, is admitted. According to the same page, the rule on public signage in Article 3 does not cover websites.

For advertising practice, the Ministry of Culture’s language department (DGLFLF) and the advertising self-regulatory body ARPP analysed almost 20,000 ads in 2018. According to this analysis, the Loi Toubon requires foreign terms to be rendered in French, “sans pour autant qu’une traduction littérale soit exigée”, without a literal translation being required; it lists English acronyms such as “DIY” among the examples of missing translations.

What does this mean for the AI label? An English-only “AI GENERATED” on a product image offered to French customers fits this framework poorly; a French word or French text next to the icon, at least as legible, fits in (our reading). Whether “IA” is also needed instead of “AI” is open: the Code allows the acronym in the national language for exactly this case but does not require it. No DGCCRF statement on AI labels was found; its website blocked automated access on 1 October 2026.

Poland: the Polish Language Act

The Polish Language Act (consolidated text Dz.U. 2026 poz. 81) applies to consumer transactions where the consumer lives in Poland when the contract is concluded and the contract is performed in Poland (Article 7(1)). It expressly also covers information “których obowiązek sporządzenia lub podania wynika z odrębnych przepisów”, which other provisions require to be provided (Article 7(3)).

• What has to be in Polish (Article 7a(1)): among other things, the names of goods and services, offers, “ostrzeżeń i informacji dla konsumentów wymaganych na podstawie innych przepisów”, that is warnings and consumer information required by other provisions, and information on the properties of goods; for the latter, the obligation also applies to advertising.
• Foreign language only in addition (Article 7a(2)): foreign-language offers and consumer information must at the same time be provided in a Polish version.
• Graphic exemption (Article 7a(3)): such information needs no Polish description if it is given “w powszechnie zrozumiałej formie graficznej”, in a generally understandable graphic form. If a description accompanies the graphic, it has to be in Polish.
• Exceptions (Article 11): among others, proper names, trade marks and “zwyczajowo stosowanej terminologii naukowej i technicznej”, customary scientific and technical terminology.
• Sanctions (Article 15(1)): anyone who provides such consumer information “wyłącznie w języku obcym”, exclusively in a foreign language, is liable to a fine. Enforcement lies with, among others, the President of the consumer protection authority UOKiK and the Trade Inspection (Article 7b).

The amendment of 30 April 2026 (Dz.U. 2026 poz. 676, in force from 1 January 2027) only concerns language certificates, not these articles.

For the AI label, it seems likely that it is consumer information required by another provision, namely Article 50(4) of the AI Act (our reading). Whether the acronym “AI” in a circle counts as a generally understandable graphic or as customary technical terminology is open. The word “GENERATED” is, on the most natural reading, a description that would then have to be in Polish. A Polish word or Polish text next to the English icon avoids the question, because the information is then no longer exclusively in a foreign language.

Italy: the Consumer Code

Article 9(1) of the Italian Consumer Code reads: “Tutte le informazioni destinate ai consumatori e agli utenti devono essere rese almeno in lingua italiana.” All information intended for consumers and users must be given at least in Italian. Where information appears in several languages, the Italian version must be at least as visible and legible (paragraph 2). “Espressioni non in lingua italiana divenute di uso comune”, foreign expressions that have come into common use, are allowed (paragraph 3).

The provision sits in the chapter “Indicazione dei prodotti”, whose Article 6 sets the minimum information on products and packaging. Whether Article 9 extends beyond such product information to an AI label on a web image, and whether “AI” is an expression in common use, is open.

Spain: the consumer protection law

Under Article 18(3) of the Spanish consumer protection law (Real Decreto Legislativo 1/2007), “las indicaciones obligatorias del etiquetado y presentación de los bienes o servicios comercializados en España”, the mandatory particulars in the labelling and presentation of goods and services marketed in Spain, must appear at least in Castilian Spanish. The provision concerns information about the goods. Whether a label that says something about the image is such a mandatory particular is open (our reading: probably not, but not ruled out).

Germany and Austria

For Germany, no law was found that generally requires German for advertising or consumer information. Distance-selling law requires information “in klarer und verständlicher Weise”, in a clear and comprehensible manner (Article 246a § 4(1) EGBGB), and obliges online retailers to state “die für den Vertragsschluss zur Verfügung stehenden Sprachen”, the languages available for concluding the contract (Article 246c no. 4 EGBGB); it therefore assumes that there can be more than one. For Austria, neither the FAGG nor the KSchG contains a general language rule; Article 8 of the Federal Constitutional Act makes German the state language of the Republic, which concerns the state, not retailers’ advertising (our reading).

So the English EU icon is not inadmissible as such in either country. The Wettbewerbszentrale, however, advises checking whether German labelling with “KI” instead of “AI” is needed, and writes that the less tech-savvy the target group of AI-generated advertising, the more likely a German label is needed; when in doubt, it recommends German terms (guide version 2.0, as of 29 July 2026). On the situation in Austria generally: Labelling AI images in Austria.

Other countries

Other Member States have language laws too, for example Latvia, whose State Language Law requires Latvian for the labelling of goods and for notices in publicly accessible places (Valsts valodas likums, Article 21). Whether they cover a label on a web image was not checked; the same goes for Belgium, the Netherlands, Lithuania, Estonia, Slovakia and all other countries not named here. National rules cannot be transferred from one country to another. For Switzerland, which is not an EU member, see Labelling AI images as a Swiss shop.

What does this mean for the label on your product image?

The four levels lead to a practical rule. It is this guide’s reading, not the legal position: the label speaks the language of the page on which the image appears. It rests on para. 142 of the guidelines (easy to understand for the person concerned), on the Code (the audience’s language proficiency, the proviso for national language law) and on the fact that all the language laws checked here allow a foreign language alongside the national one, but not instead of it.

In practice:

1. List your markets and languages. Which countries do you sell to, and in which languages does your store show its pages? A German-only store that also ships to France faces the language question for the whole page, not just the label.
2. English pages: the official EU icon fits.
3. German pages: the EU icon is not ruled out. If your customers are less tech-savvy or you are unsure, add German text or use a German word, as the Wettbewerbszentrale advises.
4. French, Polish and Italian pages: at least text or a word in the local language that is as legible as the English part. An English-only label is the riskiest option here.
5. Screen reader text in the language of the page. Alt text or an ARIA label says that the image was generated or altered with AI; spelled-out words avoid the abbreviation question.
6. Images that leave your store: a burned-in version carries its language with it. For ads and marketplaces, you therefore need a separate version for each target market (AI images on marketplaces and in ads).
7. Record your decision: which option you use in each market, and why.

In practice, platforms go by the language of their users. In the German version of its seller help, TikTok Shop describes the label that appears after switching on the AI content setting in German: “Vom Ersteller als KI-generiert offengelegt”, disclosed by the creator as AI-generated (as of 28 August 2026). The European Commission itself only provides English files. No statement of its own by a supervisory authority on the language of AI labels, beyond restating the guidelines, was found in this research (as of 1 October 2026).

The Shopify app Easy AI Act Image Labels shows the Commission’s unchanged files in English and, with Unlimited, sets the word after “AI” in your customer’s store language (24 EU languages); the acronym “AI” stays in English, and the translations are the app provider’s own, not official versions and not reviewed by any authority.

What is still open?

• Application to web labels: none of the language laws checked mentions AI labels, and by 1 October 2026 no authority or court had decided whether a label on a product image is consumer information or advertising within the meaning of these laws.
• The acronym “AI”: whether it is enough without translation in France, Poland or Italy, as an established term or a generally understandable sign, is open. The Code allows the acronym in the national language where national law rules out English, but does not say where that is the case.
• Cross-border enforcement: whether a Member State can enforce its language rules against an online store from another EU country is a separate question of EU law. The e-Commerce Directive prohibits restricting online services from other Member States for reasons falling within the coordinated field (Article 3(2) of Directive 2000/31/EC), but excludes requirements relating to goods such as labelling requirements (recital 21) and contractual obligations concerning consumer contracts (Annex). The French Ministry of Culture takes the view that the Loi Toubon also applies to offers on online sales sites. How this plays out for an AI label has not been settled.
• Translations: there are no official translations of the icon wording. Every translation, including an app’s, is a version of its own that no authority has reviewed.
• Other countries: only France, Poland, Italy, Spain, Germany and Austria were checked against the statutory text.

In short

The AI Act prescribes no language; it requires a clear and distinguishable label, and according to the guidelines that means easy to understand for the people who see the image. The Code of Practice sets the acronym “AI” in English but allows the national language where national language law rules out English, and there is no language rule for the word after it. France, Poland and Italy require their language for certain information addressed to consumers but allow a foreign language alongside it; whether this covers an AI label has not been decided. If you sell to these countries, a label in the language of the store page, or equally legible local-language text next to the English icon, is the most cautious option. For Germany and Austria, no law was found that rules out English; the Wettbewerbszentrale still advises German terms when in doubt. The guide to what Article 50 requires covers the underlying rules.