Mandatory AI labelling for clubs

Transparency requirement from August 2026

Artificial intelligence is increasingly being used to support the work of voluntary organisations and voluntary work. In this context, the transparency requirement under Article 50 of the EU AI Act – which comes into force on 2 August 2026 – is relevant. The aim is to enable people to recognise content generated or manipulated by AI.

This primarily concerns

• AI-generated images for social media
• AI-generated videos
• AI-generated audio recordings
• Deepfakes or media heavily manipulated by AI

Link to the transparency obligations under Article 50 of the EU AI Act

Please just mark it clearly

For organisations and volunteers, paragraph 4 of the EU AI Act is particularly relevant:

(4) Operators of an AI system that generates or manipulates image, audio or video content constituting a deepfake must disclose that the content has been artificially generated or manipulated. This obligation does not apply where the use is permitted by law for the purpose of detecting, preventing, investigating or prosecuting criminal offences. Where the content forms part of a clearly artistic, creative, satirical, fictional or analogue work or programme, the transparency obligations set out in this paragraph are limited to disclosing the presence of such generated or manipulated content in a manner that does not impair the presentation or enjoyment of the work.

Operators of an AI system that generates or manipulates text which is published to inform the public about matters of public interest must disclose that the text has been artificially generated or manipulated. This obligation does not apply where the use is permitted by law for the detection, prevention, investigation or prosecution of criminal offences is permitted by law, or where the AI-generated content has been subject to a process of human verification or editorial control, and where a natural or legal person bears editorial responsibility for the publication of the content.

Paragraph five further states that information should be “provided in a clear and unambiguous manner”. For associations, our colleagues at Digital vereint have interpreted this as follows: “A notice should be clearly visible and understandable. It should not be hidden away somewhere, but should appear where people see or interact with the AI-generated content.”

What about chatbots?

Chatbots too – if you use them on your websites – must be clearly identifiable, and your users must know that they are communicating with artificial intelligence rather than a human being.

Here, for example, you could have the chatbot display the following message when greeting users:

“Hello, I’m an AI assistant and I’m here to help with any questions you may have about our services.”

Always check carefully

AI is exciting and fun, but it is not infallible. Anyone who relies uncritically on ChatGPT, Claude, Gemini and the like risks, for example, contradictory articles of association or even breaches of data protection regulations.

Anyone wishing to explore the topic in greater depth can, for example, watch the recording of the presentation by lawyer Daniela Geue, ‘Artificial Intelligence – quite clever, but also quite secure? Using AI Safely in Clubs”, which she delivered on 3 March 2026 on behalf of the German Foundation for Civic Engagement and Volunteering (DSEE): visit the DSEE learning portal.