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ARTICLE · 11 SEPTEMBER 2026

AI In Advertising: Do I Need To Label My AI-generated Ad?

Browne Jacobson LLP
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Advertisers using AI-generated content face complex transparency requirements that vary significantly between the UK and EU. While UK law focuses on preventing consumer deception without explicit AI labelling mandates, the EU AI Act introduces strict disclosure obligations for 'deep fakes' that could catch even UK-based campaigns if they reach EU audiences.

European UnionTechnology

The degree of labelling necessary, if any, is going to depend on where you are and where the consumers who view the ad are. We’ve looked at the position in the UK and how UK advertisers may still be impacted by transparency requirements under the EU AI Act.

UK – to label or not to label

The UK does not have any artificial intelligence (AI) specific regulation. Uses of AI are therefore governed by existing laws, depending on the use.

The relevant advertising law is the prohibition on unfair commercial practices in the Digital Markets, Competition and Consumers Act 2024, which is also reflected in the Advertising Codes enforced by the Advertising Standards Authority. Unfair commercial practices include misleading consumers by action or omission. 

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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