09.05.2025

The first step to act against AI-generated or manipulated online content not clearly labelled as such is to report it to the online platforms where it has been published.

The use of malicious deepfake - i.e. AI-generated material without clearly and distinctly disclosing that it was artificially created or manipulated, by appropriately labelling the AI-generated result and disclosing its artificial origin - can be reported directly to platforms, using their established reporting mechanisms.

The AI Act defines a deepfake as an "AI-generated or manipulated image, audio or video content that resembles existing persons, objects, places, entities or events and would falsely appear to a person to be authentic or truthful". 

To support providers of VLOPs and VLOSEs, the European Commission has published Guidelines for providers of Very Large Online Platforms and Very Large Online Search Engines on the mitigation of systemic risks for electoral processes.

The Guidelines on the mitigation of systemic risks for electoral processes recommend the adoption of risk mitigation measures and best practices, by VLOPs and VLOSEs, before, during and after the elections. The same document (Item 5 of the European Commission Guidelines), as well as the AI Pact, recommend that VLOPs apply the AI Act before its entry into force.

Regarding the mitigation of systemic risks related to generative AI, online platforms and search engines whose services could be used to create and to disseminate AI-generated content should provide users with standard and user-friendly interfaces and tools that allow them to add labels to AI-generated content. Furthermore, adjusting the terms and conditions of use and ensuring their application is another measure to assess and mitigate the risks related to generative AI.

In order to support intermediary services users, ANCOM has published detailed information on how to report to VLOPs any issues that violates the general terms of use. More information is available in the Digital Services section of ANCOM`s InfoCenter.

It should be noted that National Directorate for Cyber Security has published a guide on identifying deepfakes, while the Permanent Electoral Authority has released a guide for preventing and combating voter disinformation actions.

It is also reminded that VLOPs are under the supervision of the European Commission or of the DSC in the country of establishment.