clearly indicated as such; and 3) when deepfakes are created using
generative AI, this fact be disclosed or indicated in a manner that
allows users to clearly recognize it. In the case of artistic or creative
works, such disclosure may be made in a way that does not interfere
with exhibition or appreciation. Under the AI Framework Act of
Korea, the subjects of these obligations are AI business operators.
Accordingly, civil society organizations that use generative AI tools
may not themselves be the direct subjects of these legal obligations.
However, given that the legal framework is still in a formative stage—
with interpretations remaining fluid and amendments likely—and
considering the underlying purpose of transparency obligations, it
would be desirable for civil society organizations that prioritize trust
and human rights to voluntarily uphold the principle of transparency
to the greatest extent possible.
However, requiring that the use of generative AI be uniformly
disclosed on all outputs is unrealistic and may impose unnecessary
burdens. As AI functions are increasingly built into internet search
engines and office applications by default, situations are emerging
in which AI is used—often to varying degrees—across a wide range
of tasks regardless of the user’s intent. In such contexts, labeling
every output with a statement such as “This output was created
with the assistance of AI” would not only create practical burdens
for organizations but also fail to provide meaningful information to
audiences.
Moreover, mechanically disclosing the use of AI for outputs that
have been thoroughly reviewed and responsibly published by an
organization may, paradoxically, undermine public trust in those
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