Does the EU AI label replace an ad disclosure? Article 50(6) says no

No. Article 50(6) says the AI Act's transparency paragraphs are without prejudice to other transparency obligations in Union or national law for deployers (Article 50, read 2026-10-02). An AI-generated label tells viewers how the content was made; an ad disclosure tells them about a commercial relationship, and the FTC's guidance wants that stated plainly too. A paid avatar video usually needs both.

Two different questions

The AI label answers "was this made or altered by AI?" The ad disclosure answers "was I paid or given something by the brand?" Each has its own wording, and one does not satisfy the other.

Putting both on one clip

Sume's video captions endpoint takes authored cues with text, start and end, which burn overlay copy without speech-to-text. You can give the ad line and the AI line separate cues so they do not collide, for example one at the top at second zero and one lower down for the same opening window.

Keep the two lines short, in different positions, and away from platform interface edges. Do not merge them into one phrase like "AI ad"; the FTC guide warns against unclear shorthand and the AI Act asks for a clear and distinguishable notice.

A pre-publish pass

• Is there a spoken or visible "ad" or "sponsored" statement in the first seconds?
• Is there a separate AI notice that a first-time viewer will see?
• Does the platform also have its own paid-partnership or AI toggle? Set it; it is not a substitute for the burned-in text.
• Is the file you publish the one you checked?

Honest limit

Whether the AI Act's label applies to a given clip depends on whether it is a deepfake or other covered content, and a deployer role is a legal question. Sume does not decide either and does not add these lines on its own.