AI Act artistic or satirical deepfakes: a lighter disclosure

If a deepfake is part of an evidently artistic, creative, satirical, fictional or analogous work, the Commission says the transparency duty is limited to disclosure "in an appropriate manner that does not hamper the display or enjoyment of the work." For an AI-made short film that can mean a modest credit rather than a banner across the picture, but the FAQ gives no format, so the choice is yours to justify.

Wording is from the Commission FAQ and its EU icons page, read 2026-10-01. This is not legal advice. The Sume part is limited to how a credit or plate can be placed; see Timeline compose and Video captions.

What does the lighter duty change?

It changes how you disclose, not whether. The duty is still disclosure, now shaped so the work stays watchable. The icons page marks the example "Fully AI-composed music or art" with an asterisk saying it "may enjoy limited disclosure requirements for artistic, creative, fictional or satirical works". The page also says the icon should be directly embedded "except for creative works", so placement has more room there.

Credit or banner: how do the options compare?

Both can be built from documented Sume endpoints. The table lists what each needs.

How small can the credit be?

The FAQ sets no size, but the icons page asks for a clearly visible size and, for a disclosure shown for a limited time, enough time to be read and understood. Sizing and duration are covered in how long on screen. A credit nobody can read does not meet "appropriate manner", so test it on a phone.

What if the work is not evidently artistic?

Then the lighter standard may not apply and the first-exposure rule from the FAQ is the safer reading. A fictional frame has to be evident to the audience, not just intended by you. When in doubt, ask counsel.