Source record
A paid relationship
The FTC's endorsement guidance addresses material connections that could affect how an audience evaluates a recommendation. Its 2023 revision explicitly encompassed virtual influencers, and the accompanying announcement cautioned that a platform's built-in disclosure tool may be insufficient. A synthetic-character label does not tell the audience that a brand paid for a recommendation.
Evidence: Federal Trade Commission [s2] · Federal Trade Commission [s3]
Source record
Generated content and direct interaction
The European Commission's guidance, updated 6 August 2026, states that Article 50 transparency obligations apply from 2 August 2026. It distinguishes obligations of AI providers and deployers, including informing people about direct AI interaction, machine-readable marking, and disclosure in specified synthetic-content contexts. Scope, exceptions and implementation depend on the actual system and use; every illustrated avatar is not automatically the same legal category.
Evidence: European Commission [s1]
Practical application
Design a three-part brief
For each placement, write three plain statements before production: who funds it, what the audience sees or hears that is synthetic, and what kind of system answers if they interact. Then assign a person to check how each statement survives publication. A brand caption, a video label and an opening chat notice may belong in different places.
Test the exported asset in the actual viewing format. A legible desktop disclosure may disappear in a cropped vertical repost. A sound-only audience cannot read a caption. A conversation that begins through a shared link may skip the account biography entirely. These are practical review prompts; the exact notice wording and placement need review against the applicable rules.
Editorial analysis
Keep responsibility visible inside the team
A creator, agency and advertiser may each assume someone else owns the final label. Put the responsible reviewer in the brief and retain the approved version. When a sponsor requests a new edit, compare the image, claim and disclosure together instead of treating the label as a one-time upload setting.
The strongest operational record connects the script to the supporting product evidence, the rights record and the delivered file. It should also identify who can correct or withdraw the asset. This makes the process repeatable without implying that a checklist resolves every jurisdiction's advertising, consumer or intellectual-property rules.
Source ledger
What this rests on.
- Guidelines on transparency obligations for providers and deployers of certain AI systems ↗
European Commission · Primary source
Source publication: Not stated by source · Source updated: 6 August 2026 · Reviewed: 16 September 2026
Commission page confirms Article 50 applies from 2 August 2026 and distinguishes provider/deployer duties, marking, direct AI interaction and deepfake disclosure, with scope and exceptions in linked guidance.
- FTC's Endorsement Guides: What People Are Asking ↗
Federal Trade Commission · Primary source
Source publication: Not stated by source · Reviewed: 16 September 2026
Guidance on material connections, clear and conspicuous disclosures and limitations of platform tools; describes the 2023 guides revision.
- Updated Advertising Guides to Combat Deceptive Reviews and Endorsements ↗
Federal Trade Commission · Primary source
Source publication: June 2023 · Reviewed: 16 September 2026
Historic official announcement explicitly includes virtual influencers in its revised endorsement definition and warns that built-in disclosure tools may not be adequate. Only month precision is retained here.
