A Finnish public organization used AI-generated images on LinkedIn and Instagram to support its public communications. The images looked professional and the campaign appeared to be working as intended. But one important detail was missing: the marketing team had not disclosed that the images had been created with AI, as required by the EU AI Act’s transparency obligations.
Later that week, a journalist contacted the organization with difficult but reasonable questions. Had the organization assessed whether the images could be used lawfully? Had it considered its transparency obligations? And by presenting AI-generated images without disclosure, was it unintentionally misleading the public?
The journalist was preparing an article about the EU AI Act’s new obligations and was looking for practical examples of what compliance would mean in everyday communications. Suddenly, a routine marketing decision had become a reputational risk.
The marketing director had not been aware that the organization’s use of AI-generated content could create a transparency obligation. Neither had the chief executive.
The issue could now be raised in a public council meeting, where elected officials, stakeholders, journalists, and members of the public might ask why the organization had not identified the requirement earlier. This shows that a routine marketing decision can become a reputational and governance issue.
To avoid similar exposure, Regulyn recommends a few practical steps. Start by mapping how AI is used across the organization, identifying which use cases require transparency, and planning appropriate disclosure methods. Just as importantly, document the assessment and the decisions that follow, creating a clear record of how each use case was reviewed and why a particular disclosure approach was chosen.
That preparation matters. If a council member, journalist or member of the public asks you the same question, your organization is not forced to respond from memory or start investigating under public pressure. You can explain how AI is used, which transparency requirements apply, what disclosures are provided, and how compliance is monitored over time.
The lesson is not that organizations should avoid AI-generated content. It is that AI use should be identified, assessed, and governed before it becomes a public issue.
Transparency is easier to build into communications workflows than to explain after a journalist or a member of the public has already found the gap.
Regulyn supports clients with AI compliance, including the AI Act’s transparency obligations. We help organizations map their AI use, identify relevant requirements, assess specific use cases, and document the decisions behind their compliance approach.
You can stay focused on your core work while we translate complex regulatory guidance into clear, practical steps and actionable assessments. Contact Regulyn today to start preparing before a compliance gap becomes a public issue.