Set approval rules by the risk of the finished marketing asset—not simply by whether AI touched it. Give every asset an accountable content owner, route claims and sensitive material to reviewers with the right expertise, decide separately whether consumer-facing disclosure is required, and keep the approved version with its evidence and sign-offs. The FTC’s advertising guidance makes clear that using AI does not remove an advertiser’s responsibility: claims must be truthful, non-deceptive or unfair, and evidence-based.
Start with a written policy and a clear scope
Define “AI-assisted” broadly enough to cover how your team actually creates and delivers marketing. Include drafted or transformed text, generated or edited images, audio and video, synthetic voices or likenesses, testimonials and reviews, and AI-powered chat assistants. Decide whether internal drafts, brainstorming, and employee-only tools follow the same approval gates as material customers can see. A practical policy can apply lighter checks to internal work while requiring the full release process for consumer-facing assets.
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For each campaign, identify the accountable content owner—the person who must ensure the final asset is ready to publish—and the people who can approve specific risks. Separate these responsibilities where possible: a brand reviewer can approve tone and identity, but that approval should not be treated as proof that a product claim is substantiated or that a disclosure is legally sufficient.
The IAB Framework V2 covers multiple media forms and consumer-facing interactions, but it is industry guidance, not a universal legal rule. Likewise, NIST’s AI Risk Management Framework is voluntary guidance for incorporating trustworthiness into AI design, development, use, and evaluation; it does not prescribe a marketing sign-off chart.
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Use risk tiers to decide who approves
The following is a workable internal model, not an approval matrix mandated verbatim by the FTC or NIST. A team can adjust the routing to its products, markets, and risk tolerance.
| Tier | Typical content | Minimum review before release |
|---|---|---|
| Routine | Formatting, spelling, low-stakes ideation, or ordinary copy with no material factual claim. | A trained content owner checks brand fit, obvious errors, and whether the asset matches the brief. |
| Claims-bearing | Product benefits, performance, comparisons, price or availability, environmental claims, and measurable outcomes. | The owner of the claim checks the evidence and approves only wording and qualifications the evidence supports. Brand review remains a separate check where needed. |
| Elevated risk | Health or financial claims; endorsements, testimonials, or reviews; material aimed at children or other sensitive audiences; and synthetic depictions or voices that could mislead about a person. | Route to the relevant subject-matter, legal, privacy, or compliance reviewer before publication, in addition to the content owner and any claim owner. |
Use the highest applicable tier when an asset spans categories. For example, a routine social caption that includes a specific investment-return claim is not routine for approval purposes. The FTC identifies endorsements, reviews, children’s marketing, and health claims as areas that warrant particular attention; specialized categories can have additional rules.
Make claim review about the final wording and evidence
For every objective claim, the reviewer should be able to identify what supports it and whether that support covers the precise wording in the final asset. A source that supports a qualified statement does not automatically support a stronger headline, comparison, image, or voiceover. Review claims in context, including captions, footnotes, landing pages, and visual or audio elements that change the impression an audience is likely to take away.
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- Is each factual claim accurate and supported by appropriate evidence?
- Does the final wording stay within that evidence, including qualifiers, comparisons, dates, and conditions?
- Could the claim trigger additional requirements because it concerns health, finance, the environment, origin, performance, or a specialized product category?
- Could an image, voice, quote, testimonial, or chatbot exchange mislead people about who said or did something, or whether an endorsement is genuine?
- Does the finished asset still match the version and evidence that reviewers approved?
The FTC’s Advertising and Marketing guidance states: “Under the law, claims in advertisements must be truthful, cannot be deceptive or unfair, and must be evidence-based.” Treat that as a release standard for AI-assisted claims as well as human-written ones.
Apply extra safeguards to endorsements, testimonials, and reviews
Do not use generated material to create a false impression that a real customer had an experience, said particular words, or endorsed a product. Treat AI-generated or AI-edited endorsements, testimonials, and consumer reviews as elevated risk, and verify authenticity, permissions, and the basis for any claims before use. FTC guidance addresses endorsements and influencer marketing, native advertising, and the Consumer Reviews and Testimonials Rule.
Where an endorsement has a material connection that requires disclosure, check that the disclosure is clear and conspicuous in context. For example, FTC guidance says an affiliate disclosure should be close to the recommendation and link; burying it in comments is avoidable and may not be clear and conspicuous.
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Make a separate disclosure decision for each market and asset
Do not treat internal AI use as an automatic duty to label every ad, and do not assume that no label is ever needed. Before release, record the target market and channel, the media form, how AI affected what consumers see or hear, whether a person or interaction could be mistaken for real, and the applicable law and platform terms. Distinguish provider obligations from deployer obligations where the governing rule does so. The legal position depends on jurisdiction, activity, medium, and context.
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The IAB’s August 18, 2026 Framework V2 recommends a risk-based, materiality-driven approach. Its examples for disclosure consideration include generated images and videos, some synthetic voices and avatars, certain digital twins, and chatbots that could be mistaken for humans. Under the IAB framework, routine production uses and text or copy do not automatically require labels. The IAB is an industry association, and its framework does not replace applicable regulations or platform rules.
For EU-facing work, consolidated AI Act Article 50 distinguishes provider marking of covered synthetic outputs from deployer disclosure for deepfakes and certain public-interest text. Its scope includes conditions and exceptions; for public-interest text, the cited provision contains an exception where human review or editorial control occurs and a natural or legal person holds editorial responsibility. The Act states that it applies from August 2, 2026. That does not mean every AI-assisted marketing asset must be labeled: determine whether the particular asset and activity fall within the provision.
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Consumer expectations can inform, but cannot decide, the legal question. IAB reported that more than half of respondents in January 2026 research with Sonata Insights wanted brands to disclose when an ad was fully AI-generated or used AI imagery or video. In the same research, 73% of Gen Z and Millennial respondents said clear disclosure would increase or have no impact on their likelihood to purchase. IAB reported these figures in its August 18, 2026 announcement; the announcement excerpt does not provide sample size or full methodology, so the findings should not be treated as representative of every consumer or as a source of legal obligations.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Use a release sequence that leaves a trace
A policy becomes usable when reviewers know what they are being asked to approve and the team can later show what actually went live. A lightweight sequence can look like this:
- Register the asset. Give it a campaign or asset ID and record intended channel, audience, and target market.
- Assign ownership and tier. Name the accountable content owner, identify claims or sensitive content, and route the asset to the highest relevant tier.
- Attach the basis for claims. Link or attach the supporting evidence and identify the exact claims it substantiates.
- Review the finished material. Check claim accuracy, evidence fit, brand requirements, misleading representations, and any applicable category-specific rules.
- Record the disclosure decision. Note whether a consumer-facing disclosure is required, what it says and where it appears, or why one is not required under the applicable rule and context.
- Approve the release version. Store the final copy or media with reviewer names and roles, decision dates, conditions, and revision history. Publish only that version.
Keep the approval record with the asset rather than in an unconnected chat or email thread. At minimum, retain the final version, supporting claim evidence, reviewer identity and role, approval date, and disclosure decision. A campaign or asset ID, market and channel, material AI use if tracked by your policy, and revision history make it easier to connect the decision to the publication.
Escalate when the approved basis changes
Pause release and reopen the relevant approvals if the claim, offer, target audience or market, output medium, or material representation changes. A rewrite can strengthen a claim; a new crop, voiceover, avatar, or caption can change an asset’s meaning; and a new jurisdiction can change disclosure or legal requirements. Route only the affected questions back to qualified reviewers, but do not assume an earlier sign-off covers a materially different final asset.
For a small team, this can be a shared approval form and a controlled folder; a larger team may use workflow software to route reviews and preserve decisions. The important control is not the tool: it is a traceable connection between the version published, the evidence reviewed, and the people who approved it.
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