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AI Act in Spain: High penalties for lack of labeling of AI-generated content

On March 11, 2025, the Spanish government passed a draft bill on the AI Act, which obliges companies to clearly label AI-generated content. Violations could result in significant fines, as reported by Reuters.

Key points:

  • Companies must clearly label AI-generated content.
  • Violations could result in fines of up to 35 million euros or 7% of annual global turnover.
  • The law is particularly aimed at combating the dissemination of “deepfakes”.
  • Spain is thus implementing the guidelines of the EU AI Act.

Background to the law

With the rise of artificial intelligence (AI) and the increasing spread of “deepfakes” – manipulated media content created by AI algorithms – there is growing concern about their potential misuse. Such content can be used to spread misinformation and influence public opinion. To counteract this, Spain has decided to introduce strict measures to regulate AI-generated content.

Content of the draft law

The new draft law stipulates that companies are obliged to clearly label any AI-generated content as such. Companies that fail to comply with this obligation will be committing a “serious administrative offense” and can be fined up to €35 million or 7% of their annual global turnover. This regulation aims to create transparency and prevent the dissemination of misleading information.

In addition, the law prohibits the use of subliminal techniques – i.e. stimuli that are imperceptible to the conscious mind – aimed at manipulating the behavior of vulnerable groups. One example of this is chatbots that could incite people to engage in harmful behavior.

Implementation and monitoring

Compliance with the new regulations will be monitored by the newly created Spanish supervisory authority for AI, AESIA. This authority is responsible for ensuring that companies comply with the established guidelines and imposing appropriate sanctions in the event of violations.

European context

Spain is one of the first countries in the European Union to implement the directives of the EU AI Act. This legal framework is considered one of the most comprehensive in the world and sets out strict transparency requirements for AI systems that are classified as high-risk. In contrast to the USA, which largely relies on voluntary commitments and inconsistent state regulations, the EU takes a stricter approach to regulating AI.

Conclusion

With this draft law, Spain is sending a clear signal for more transparency and responsibility in dealing with AI-generated content. Companies are now required to label their content accordingly in order to strengthen public trust in digital media and curb the spread of misinformation.

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