IAB refines AI disclosure guidance to focus on material changes in advertising authenticity

The Interactive Advertising Bureau has updated its guidance on AI disclosure, emphasising the importance of transparency when technology materially alters consumer perception, amidst evolving global regulations and market fragmentation.

The Interactive Advertising Bureau has updated its guidance on when AI use in advertising should be disclosed to consumers, setting out a more selective approach that focuses on whether the technology materially changes authenticity, identity or representation. In its new framework, the trade body says not every use of generative tools needs a label, only those that could reasonably alter what an audience believes is real.

The revised standard reflects a market that has become more fragmented since the first version was issued in January. According to the MarTech report, disclosure rules have since taken effect in jurisdictions including California, New York, South Korea and the European Union, making it harder for brands to apply a single policy across campaigns. The IAB says its framework is intended to give advertisers, agencies, publishers, platforms and technology companies a common way to assess when disclosure is required.

Under the guidance, realistic synthetic material is the clearest case for disclosure. That includes generated images and video, some synthetic voices and avatars, digital twins of deceased people, and digital replicas of living people placed in fabricated scenarios outside normal brand endorsements. Chatbots and assistants should also be identified as AI when consumers could reasonably think they are dealing with a human representative.

By contrast, the IAB treats many behind-the-scenes uses of AI as unlikely to require consumer-facing disclosure. Routine post-production work, internal workflows, copy drafting, standard audio enhancement, background music and obviously stylised avatars generally fall outside the automatic-disclosure threshold. The framework’s central argument is that disclosure should depend on the effect of the technology, not simply on the fact that AI was used somewhere in the production chain.

The IAB says the approach is informed by consumer research carried out with Sonata Insights for the original framework. That work found mixed attitudes towards AI in advertising, but more than half of respondents said brands should disclose when an ad is fully generated by AI or contains AI-generated imagery or video. The trade body presents that as support for targeted disclosure rather than universal labelling.

The new guidance also arrives as regulators move in different directions. New York’s synthetic performer law took effect in June, while California’s SB 942 and Article 50 of the EU AI Act came into force on 2 August. The EU rule requires disclosure for covered AI-generated content and deepfakes, but does not mandate a specific icon, whereas the IAB’s recommendation for US advertisers is either a standard sparkle icon or clear text, subject to local legal requirements.

Taken together, the framework turns AI disclosure into a detailed compliance exercise. Marketers now need to know not only whether AI was involved, but what it changed, whether it affected how a person, product or scene would be perceived, where the content will appear and which jurisdiction’s rules apply. The IAB’s message is that transparency should be precise, not automatic.

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