Disclose synthetic content while retaining separate: Which implementation best addresses the stated
Synthetic-content disclosure is required here, but it does not replace separate documentation, oversight, or cybersecurity duties.
The question
An insurer uses an EU AI Act system to generate synthetic images for customer-facing claims communications. Assume the relevant EU AI Act transparency obligation for this synthetic content applies. Separate documentation, human-oversight, and cybersecurity duties also remain applicable. Which implementation best addresses the stated transparency requirement without displacing those duties?
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- Record the model’s training sources internally.Training-source records may support other obligations, but they do not disclose to recipients that customer-facing content is synthetic.
- Disclose synthetic content while retaining separate governance controls. ✓A customer-facing disclosure addresses the assumed transparency duty while preserving independent documentation, oversight, and cybersecurity obligations.
- Disclose synthetic content and treat the notice as replacing documentation, oversight, and cybersecurity controls.Transparency is one control category and cannot replace separate applicable evidence, human-oversight, or security measures.
- Train claims staff to review generated images.Staff instructions support human oversight, but they do not provide the required recipient-facing disclosure about synthetic content.
The trap
Treat disclosure as one duty, not as a substitute for the rest of the control framework. How to remember it
Synthetic-content disclosure is required here, but it does not replace separate documentation, oversight, or cybersecurity duties.
How many of these would you get right?
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