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ARTICLE · 10 NOVEMBER 2026

When Does An AI-generated Advert Need An AI Label? Not Always, Says EASA

Lewis Silkin
Lewis Silkin
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Lewis Silkin

Lewis Silkin

Joint managing partners: Jo Farmer, Richard Miskella International offices: Dublin, Hong Kong...

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The European Advertising Standards Alliance has published new guidance on AI transparency in advertising, challenging the assumption that every AI-touched advertisement requires disclosure. The framework introduces a three-factor test examining the extent of AI use, realism of output, and significance to consumer understanding. This approach aims to prevent disclosure fatigue while maintaining meaningful transparency standards.

United KingdomMedia, Telecoms, IT, Entertainment

In its new Guide on Disclosing Ads Generated or Enhanced with Artificial Intelligence, EASA argues that AI transparency should be meaningful rather than automatic. As AI becomes embedded throughout the advertising process, the challenge is balancing consumer trust with the risk of overwhelming audiences with labels that add little practical value.

It points out that AI is increasingly embedded throughout advertising production, from ideation and creative development to the final execution of an advertisement. This creates new opportunities for creativity and innovation, but also raises important questions about authenticity, transparency and the information consumers need to understand the commercial content they see. 

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