As a rule yes, for AI-generated images made available to the public. The EU AI Act requires synthetic image, audio and video to be marked in a machine-readable form and the user to be told that the content is artificial. Providers must mark the output; deployers who publish deepfakes carry their own duty to disclose. Both apply from 2026, and if you put content on the EU market they can reach you as well.
Disclosure matters most where the content imitates real people or real events. The exceptions — an obviously artistic or fictional context, for instance — are read narrowly, and the test is always whether the content misleads. In Türkiye there is a further layer: the Personal Data Protection Law (No. 6698), together with the general rules on personality rights and on tort, creates separate liability for generating the image of a real person without their consent. In practice the safer course is a consistent labelling policy with a record of content provenance, built into the generation pipeline rather than added afterwards.
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