A 3D render created without AI does not require an AI content label under Article 50 of the AI Act. This also applies to visualizations created at Pogotowie 3D by modeling and rendering a scene without artificial intelligence.

In this process, we prepare a product model, apply materials and set up lighting and the camera. The software calculates the finished image from this scene. A photorealistic product visualization may look like a photograph, but this appearance alone does not create an obligation to label it as AI.

Legal basis: Article 3(1) and Article 50 of Regulation (EU) 2024/1689.

What if AI assists with a render?

Image denoising and generating new surroundings are different applications. When improving quality, it is necessary to check whether the tool preserves content or adds details. Article 50(2) provides an exception for standard assistive editing or where input data or its meaning are not substantially altered. It concerns the tool provider's obligation.

If AI adds people to a product presentation or changes the appearance of an existing place, we assess the obligation to disclose a deepfake separately. It does not automatically arise from every use of AI. Publication context also matters, as does whether viewers might wrongly consider the content authentic.

Legal basis: Article 50(2) and (4). See the Commission's transparency guidelines and the official FAQ.

What does deepfake mean in a product presentation?

Under the AI Act, a deepfake is an image, recording or video created or altered by AI that resembles an actual person, object, place or event and could be mistaken for authentic. For example, AI creates an image of a particular armchair in an existing hotel, and the publication presents it as a photograph of furnishings actually installed there, although the armchair was never there.

Such material may meet the definition of a deepfake. The image must be assessed together with its description and publication context. An ordinary render made without AI does not become a deepfake under the AI Act merely because it looks realistic.

Legal basis: Article 3(60) and Article 50(4).

Which watermarks and labels are used?

Information about AI can be visible on an image or stored in the file for an appropriate tool to read. Several solutions are used:

• Visible text or a label, such as “Generated using AI” or “AI generated”. It may appear on the graphic or immediately alongside it. The label on the right side of this article's header is an example. A studio logo or author credit alone does not indicate AI use.
• An invisible digital watermark, for example SynthID. It is embedded in the image and detected by a compatible tool. Viewers do not see it as text in the corner of the graphic.
• File provenance data, for example Content Credentials based on the C2PA standard. These are digitally signed details about the creation and editing of material that can indicate AI involvement. They are not the same as a visible watermark.

The European Commission also provides icons for labeling AI content. Article 50 does not prescribe a single wording or graphic symbol for all images.

Machine-readable marking concerns the AI system provider's obligation. Where a deepfake must be disclosed, the AI deployer must also ensure information is clear to viewers, at the latest when the material is first shown. A hidden mark or metadata alone does not replace that notice.

Legal basis: Article 50(2), (4) and (5); European Commission FAQ.

How do we inform Pogotowie 3D clients?

When delivering finished visualizations, we inform clients whether and to what extent AI was used. If AI use involves legal labeling obligations, we explain which obligations apply to the client's use and publication of the graphics received.

When do the rules apply?

The AI Act, the regulation of 13 June 2024, entered into force on 1 August 2024. The transparency obligations under Article 50 apply from 2 August 2026.

Legal basis: Article 113. Providers of systems placed on the market before 2 August 2026 have until 2 December 2026 to implement machine-readable marking under Article 50(2) (Article 111). This exception does not postpone deepfake disclosure. European Commission explanation.

Legal status as of 10 October 2026. Header graphic generated by AI.