The VIFLY guide France · European Union
An AI-assisted ad must remain an honest ad.
AI can help you design a campaign. It does not turn a partnership into a spontaneous review, an avatar into a real client or an invented promise into a proven result.
Sources checked on 23 October 2026
The short answer
Advertising and commercial influence
In commercial influence, make advertising intent immediately identifiable and check image-related disclosures. An AI representation of a face or silhouette may require the French disclosure 'Images virtuelles'. Commercial transparency and AI transparency may both apply.
These guideposts distinguish the status of a rule; 'Pause and check' calls for review before acting.
Two disclosures may apply together
The partnership
Who pays you or provides a benefit?
The image
Synthetic face or silhouette?
The release
Readable disclosures in the right place.
From rule to practice
What does that look like in practice?
An avatar presents a gifted product
The content promotes a brand in a commercial relationship.
Check advertising identification, 'Images virtuelles' where its conditions apply and other relevant rights.
A completely invented before-and-after
The image claims to demonstrate real effectiveness.
Do not present it as an achieved result. A simulation must be identified and must not make a misleading promise.
An abstract poster with no person
AI creates a graphic composition for a campaign.
Check licences and advertising rules; do not automatically infer an 'Images virtuelles' duty where there is no face.
Making the commercial relationship visible
Payment, a gift or an affiliate commission may establish a commercial relationship depending on context. People must understand the advertising nature without searching at the end of a caption or interpreting an ambiguous hashtag. The French DGCCRF cites disclosures including 'Publicité' and 'Collaboration commerciale'.
Also identify the brand or advertiser. For a video or story, adapt visibility to the medium and the duration required by applicable rules. A platform's partnership setting is useful, but check that people actually receive clear information.
Virtual and retouched images
Under the French commercial influence framework, the disclosure 'Images virtuelles' concerns AI processes representing a face or silhouette. The disclosure 'Images retouchées' concerns image processing intended to slim or thicken a silhouette or alter a face's appearance within that framework.
Do not automatically extend these two disclosures to every AI-assisted drawing posted anywhere. However, if another transparency regime applies, such as an Article 50 deepfake, address that duty too. A simple 'AI' label may be insufficiently precise for your case.
Do not invent experience or results
A fake client testimonial, fabricated before-and-after image or imaginary professional presented as real may mislead consumers. An AI label does not correct a false claim about a product's quality, effectiveness, origin or price.
To illustrate a mechanism, clearly identify the simulation. Keep evidence for commercial claims and check sector-specific rules: health, finance, gambling, training and other regulated activities. Client approval does not remove your responsibilities.
Preparing a usable handover
Agree in writing on channels, duration, territories, personal permissions and media licences. Specify who adds and checks disclosures on each publication. A cropped or reposted extract may lose information visible in the original.
Supply the necessary materials: final version, disclosures to retain, permissions, claim evidence and reuse limitations. For a sensitive campaign or an imitation of a person, have the project reviewed before production and release.
Wording to get started
Disclosures to adapt to your case.
These examples are neither official forms nor a compliance guarantee. Check the wording, placement and display duration required. French statutory disclosures are retained in the examples.
Example for a collaboration using an avatar
Publicité — [brand]. Images virtuelles: AI-generated character.
Text copied. Adapt it before use.Copy unavailable: select the text to copy it.
Before taking action
Your essential checks.
A preparation aid, with no automatic compliance verdict.
Getting to the point
Questions people often ask.
Does an AI label replace 'Publicité'?
No. One explains the process, the other the commercial intent. Both duties may apply to the same content.
Must every generated image say 'Images virtuelles'?
This French disclosure has a specific scope, notably commercial influence using AI to represent a face or silhouette. Other rules may require transparency in other situations.
Sources and method
The sources behind the answers.
Editorial team: VIFLY. Documentary checks on 23 October 2026. This guide is an educational summary without individual legal validation. The links let you consult the text and its conditions.
- European CommissionAI Act — Article 50: transparency Legal text
- DGCCRFCommercial influence: disclosures and duties Official explanation
- French Ministry of EconomyCommercial influence good practice guide 2026 Official explanation
- Service PublicImage rights and privacy Official explanation
- LégifranceFrench Intellectual Property Code — Article L111-1 Legal text
- DGCCRFMisleading practices and fake reviews online Official explanation
Understand, then practise
Clear rules. Useful applications.
Explore AI courses and VIFLY resources to build a more considered practice.