"Do we have to label content created with imc Express as AI-generated?"

You do not have to add anything yourself. imc Express discloses the use of AI automatically. The only thing you configure is whether an additional visible notice appears on the start page.

What imc Express labels automatically

• Metadata in every output. Every piece of AI-assisted content carries a machine-readable provenance record – in web delivery as well as in the SCORM package, the PDF export and the accessible output. The content is technically detectable as AI-assisted without any change to how it looks.
• AI images. Images generated with AI are labelled on the image itself.
• All output formats, including the accessible output. The AI notice is also present in the text channel – where screen readers read it out. It is not visual only.

What you can configure

In the project settings you switch the visible notice on the start page on or off. We recommend leaving it on: it costs nothing and answers your learners' question before they ask it. Labelling in the metadata and on AI images is unaffected by this setting.

Why this setup is sufficient

The EU AI Act requires visible labelling of AI-generated text only where it is published to inform the public on matters of public interest (Art. 50(4)) – and not even then, if the text has undergone substantive human review and a person holds editorial responsibility. That is exactly how imc Express works: no AI suggestion is published without your approval. A purely formal check (spelling only, for example) is not sufficient.

For images, the labelling obligation applies to photorealistic depictions – even where the person or place shown is entirely invented. imc Express covers this case automatically.

For speech output, no labelling obligation applies. imc Express only uses synthetic voices that do not reproduce a real, identifiable person; voice cloning and uploading your own voice samples are not possible. The AI Act's deepfake definition is therefore not met.

Machine-readable marking is an obligation of the provider, not yours – imc fulfils it.

What stays in your hands

The professional judgement. Airis makes suggestions – you decide which of them become learning content. That is precisely why no labelling obligation arises for your text: the final call always rests with someone who knows the subject. And it is the same reason your courses hold up professionally.

You keep full authority over the content – its wording, its depth, and what applies in your organisation.

This information provides a general overview and does not constitute legal advice.