Mandatory labels required for AI-generated content

Starting from May, organisations and individuals deploying artificial intelligence (AI) systems are required to clearly disclose AI-generated or AI-edited content that may cause confusion over the authenticity of events or persons or the origin of content, according to Decree 142/2026/ND-CP recently issued by the Government.

The labelling requirement applies to audio, images and videos generated or modified by AI systems when such content simulates or imitates the appearance or voice of real persons, or recreates real-world events in a manner that could be mistaken for authentic content.

Labels or notifications must be clear, easy to understand and easy to recognise, and must be displayed before or at the time users access the content. They must not be designed in a way that conceals or reduces users’ ability to recognise the nature of the content, or significantly obstructs the display, presentation or use of the content.

However, labels or notifications are not required for technical edits made solely to improve the quality of audio, images or videos, provided such edits do not change the nature or context of the content. Texts processed with AI tools for spelling correction, grammar editing, summarisation, paraphrasing or translation are also exempt, as long as the original meaning remains unchanged.

Other exemptions cover content used exclusively for internal purposes within agencies, organisations or enterprises and not publicly distributed, as well as content created during research, development or testing activities in controlled environments and not released to the public.

Regarding disclosure methods, the decree allows AI-system deployers to use different forms of labelling or notification depending on the type of content and method of delivery.

Labels and notifications may be placed directly on the content, in titles, captions or descriptions, on platform interfaces, through audio announcements, or by other appropriate means. For films, art performances and creative works, they may appear in opening sections, end credits, title sequences, descriptions or accompanying materials, depending on the nature of the work.

For AI-generated or AI-edited content produced through multiple stages, the entity responsible for creating or editing the content must provide the information necessary for labelling or notification. Those directly releasing the content to the public will be responsible for fulfilling disclosure obligations based on the information received.

The Ministry of Science and Technology is tasked with issuing and updating technical guidance on notification and labelling methods. The guidance must not introduce new administrative procedures, business conditions or obligations beyond those already provided in the decree.

- (VLLF)