AI generated ads and the UK advertising rules: when to disclose, and when a label does not help

The short answer

There is no blanket duty to label AI generated advertising in the UK. The Advertising Standards Authority's test is whether the audience is likely to be misled if the use of AI is not disclosed. Where they would be, disclose. But disclosure does not rescue an ad that is misleading anyway: an image of a product or its results has to be true.

Regulator

The Advertising Standards Authority

Rules

The CAP Code and the BCAP Code

AI specific rules

None. The existing rules apply

Who is responsible

The advertiser

The disclosure test

The ASA suggests asking whether the audience is likely to be misled if the use of AI is not disclosed, and what mischief the disclosure would prevent. An AI generated influencer who appears to be a real person is a case for saying so. A true sentence of copy that a tool helped to write is not.

Why a label is not a cure

The ASA says disclosure alone is very unlikely to mitigate the harm of a fundamentally misleading message. Its example is a cosmetic product: an AI image showing an effect that does not reflect real results is likely to be materially misleading, and saying it was made with AI does not change that. The same applies to a room shown larger than it is or a before and after picture that is not real.

Real people and responsibility

Using a real person's face or voice without permission to suggest an endorsement breaks the rules on testimonials and may breach other law. An invented customer with an invented quote is a fake testimonial. And the advertiser answers for the ad whether an agency, a tool or a platform's automatic system produced it.

Learn it properly, free

This guide is the summary. The course teaches it in full, with a video conversation, worked scenarios and a knowledge check after each module. Every module is free to read with no account. A certificate, if you want one once you pass, is £9.

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