Does an AI avatar at an event have to be labeled?

01The law

What the law requires

The rules are in Article 50 of the EU regulation on artificial intelligence, the AI Act. Three of its paragraphs matter for AI avatars at events.

• 2.8.2026Article 50 appliesArticle 113 of the AI Act
• 15 M €maximum fineor 3 % of worldwide annual turnover; proportionate for SMEs
• 2.12.2026marking for older systemsfor systems already on the market before 2.8.2026

• Paragraph 1 · provider

  Disclose that it is an AI

  Whoever provides an AI system that interacts directly with people must design it so that those people are informed they are interacting with an AI. This only falls away when it is obvious to a reasonably well-informed, observant person. The European Commission’s guidelines name avatars explicitly as an example and read this exception narrowly.

• Paragraph 2 · provider

  Mark image and sound machine-readably

  Whoever provides a system that generates synthetic images, video, audio or text must mark these outputs as artificially generated, in a machine-readable format.

• Paragraph 4 · deployer

  Disclose deepfakes

  Whoever uses a deepfake must disclose that the content has been artificially generated or manipulated.

The information must be given at the latest at the first interaction, clearly and in an accessible way (paragraph 5).

02Deepfake

When an AI avatar is a deepfake

The European Commission’s guidelines name three criteria. It is only a deepfake if all three are met:

1. 01

   Resemblance

   The content closely resembles the depicted original.

2. 02

   A real original

   The original actually exists, for example a person.

3. 03

   False appearance

   The content falsely appears to be authentic.

• In our reading: not a deepfake

  An invented character

  It resembles no real person and does not meet the second criterion. Paragraph 1 still applies as soon as it talks to people.

• Deepfake

  A digital twin

  If an avatar speaks with the face or voice of a real person, for example the CEO as an avatar at a town hall, all three criteria are met as soon as the audience could take it for real. Then it must be disclosed that it is artificial.

For evidently artistic, satirical or fictional works, a disclosure that does not hamper the work is enough.

03Responsibility

Who has to do what at an event

In practice, this means for organizers: agree with the provider before the event how the avatar is labeled. If guests on stage talk to the avatar, they should know before the conversation starts. And whoever has a real person recreated must disclose the recreation.

04Switzerland

And in Switzerland?

Switzerland is not part of the EU and has no AI law of its own yet.

• 12.2.2025Federal Council decisionto ratify the Council of Europe’s AI convention and adapt Swiss law where needed
• End of 2026draft for consultationprepared by the Federal Office of Justice

The AI Act can still apply. It also covers providers and deployers from outside the EU if the output of their AI system is used in the EU (Article 2(1)). If a Swiss AI avatar appears at an event in Germany or Austria, the rules above apply.

05Aura51

How we label

All four Aura51 characters are AI avatars, and that is how our site presents them. They were created entirely virtually and are not modeled on any real person, living or dead. In our reading, they are therefore not deepfakes.

They are labeled all the same: the video on the screen can be permanently labeled as an AI avatar, visible to the guests on stage, to the audience and to a livestream.