Apps that use artificial intelligence to create content must tell users clearly when that content is AI-generated and cannot use AI to mislead or deceive people.
This analysis describes what Apple's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This requirement establishes disclosure obligations that condition app availability on the App Store, creating a procedural mechanism for transparency about AI-generated content generation capabilities and potential synthetic content risks.
Consumers using apps that generate text, images, audio, or video with AI must be clearly informed that the content is AI-generated, reducing the risk of being deceived by synthetic media or deepfakes.
How other platforms handle this
After registration, you may create, upload or transmit files, documents, videos, images, data or information as part of your use of the Service (collectively, "User Content"). This includes any inputs you provide to our AI-powered support tools and outputs generated in response to your inputs. User ...
Microsoft commits to transparency about when users are interacting with AI systems, including disclosure of AI-generated content, notification when AI is being used in consequential contexts, and provision of meaningful information about AI system capabilities and limitations to enable informed user...
engage in any of the foregoing in connection with any use, creation, development, modification, prompting, fine-tuning, training, testing, benchmarking or validation of any artificial intelligence or machine learning tool, model, system, algorithm, product or other technology ("AI Tool").
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"Apps using AI-generated content must clearly indicate when content is AI-generated. Apps must not use AI-generated content to deceive or mislead users. Developers must disclose in their privacy nutrition labels if their app uses AI to generate content that could be mistaken for real people or events.— Excerpt from Apple's Apple App Store Review Guidelines
REGULATORY FRAMEWORK: This provision engages the EU AI Act (Regulation (EU) 2024/1689), specifically Art. 50 which mandates disclosure of AI-generated or manipulated content (deepfakes), enforceable by national market surveillance authorities. It also implicates FTC Act Section 5 (deceptive AI-generated content constitutes an unfair or deceptive practice), FTC's 2023 AI guidance, and emerging state-level AI disclosure laws (California AB 602, AB 2655 on synthetic media in elections). The provision aligns with but does not fully replicate the EU AI Act's more detailed requirements.
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This requirement establishes disclosure obligations that condition app availability on the App Store, creating a procedural mechanism for transparency about AI-generated content generation capabilities and potential synthetic content risks.
Consumers using apps that generate text, images, audio, or video with AI must be clearly informed that the content is AI-generated, reducing the risk of being deceived by synthetic media or deepfakes.
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