AI-Generated Advertising & Marketing Disclosure Compliance Check

Why this matters

UK businesses are increasingly using AI to generate product images, video ads, synthetic voiceovers, and even AI “spokespeople” or influencer likenesses — often without a clear policy on when this needs to be disclosed. The Advertising Standards Authority and its sister body, the Committee of Advertising Practice, have made clear through updated guidance on AI in advertising that the existing CAP Code still applies in full: ads must not materially mislead consumers, whether by omission or otherwise, and content that looks like a genuine customer, real footage, or an authentic demonstration but is wholly or partly AI-generated can breach Rule 3.1 if that fact isn’t made clear. The ASA has already ruled against ads using undisclosed AI-generated “before and after” imagery and synthetic testimonials, and enforcement is expected to increase as AI tools become standard in small business marketing. This sits alongside the Digital Markets, Competition and Consumers Act 2024, which gives the Competition and Markets Authority direct powers to fine businesses up to 10% of global turnover for unfair commercial practices — including misleading actions and omissions — without needing to go to court first, following its unfair trading provisions coming into force in April 2025. Fake or undisclosed AI-generated reviews and testimonials are also explicitly banned outright under the Act’s list of automatically unfair practices. For a business relying on AI to produce ad creative, product photography, voiceovers, or review content, the risk isn’t the use of AI itself — it’s failing to disclose it where doing so would change how a reasonable consumer understands what they’re seeing, and running into CMA or ASA enforcement as a result.

What you'll need

• Whether your business uses AI tools to generate or substantially edit images, video, voiceovers, or copy used in advertising or marketing
• Whether any AI-generated content could be mistaken for genuine footage, real customer testimonials, or authentic product demonstrations
• Whether your marketing includes AI-generated or AI-assisted reviews, ratings, or endorsements
• Awareness of the ASA/CAP Code rules on misleading advertising and the Digital Markets, Competition and Consumers Act 2024

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.