ASCI Issues New Guidelines for Labelling AI-Generated Content in Advertisements

New framework sets disclosure requirements for synthetic content, prohibits deceptive AI uses and exempts routine editing that does not affect consumer decisions

The Advertising Standards Council of India (ASCI) has issued new guidelines governing the responsible use and labelling of synthetically generated content (SGC) in advertisements, as brands increasingly use artificial intelligence to create, modify and enhance advertising material.

The framework sets out when advertisers must disclose that AI or other synthetic technologies have been used, identifies practices that remain prohibited even when disclosure is provided, and clarifies situations where an AI label is not necessary.

The guidelines will come into effect three months after publication. ASCI said the framework is intended to improve transparency while avoiding unnecessary disclosure requirements for low-risk uses of AI.

What is synthetically generated content?

ASCI defines SGC broadly as audio, visual or audio-visual material that is artificially or algorithmically created, generated, modified or materially altered using computer resources.

However, not every use of AI automatically falls within the disclosure requirement.

The guidelines focus on synthetic material that is designed to appear real or authentic and that depicts an individual, event or setting in a way that could reasonably be perceived as genuine.

This distinction is important because AI tools are now routinely used for activities ranging from image enhancement and advertising copy generation to the creation of realistic people, product demonstrations and virtual influencers.

When will AI-generated advertising need a label?

Disclosure becomes necessary when synthetic content materially influences a consumer's decision and the absence of disclosure could mislead the audience.

One important category is the use of synthetic influencers or ambassadors. If an AI-generated person is presented as an influencer or brand representative, advertisers will need to make the synthetic nature of the content clear.

Labelling is also required when an advertiser uses the likeness or voice of a real person with consent to create personalised advertising communications.

Other situations requiring disclosure include fabricated events or locations that could materially affect how consumers understand a product or service.

Synthetic product demonstrations

AI-generated demonstrations of products that do not actually exist also fall within the disclosure requirement when they could influence consumer understanding or purchasing decisions.

For example, an advertisement showing a realistic demonstration of a product feature that has not actually been developed could potentially create a misleading impression if viewers are not told that the demonstration is synthetic.

ASCI's framework also specifically covers AI-generated sound effects when they are highly relevant to a product's core characteristics, such as specially created audio in an advertisement for headphones or other sound-related products.

What uses are prohibited?

An AI label does not make misleading advertising acceptable.

Advertisements that violate the ASCI Code, applicable law or intellectual-property rights remain prohibited regardless of whether the advertiser discloses the use of synthetic content.

The framework specifically identifies several problematic practices.

These include fabricated endorsements and testimonials, misleading representations of product performance, unauthorised use of a person's likeness, deepfakes and use of copyrighted material without appropriate authorisation.

Advertisements also cannot present fictional locations or events as real when doing so could mislead consumers.

This means disclosure is not a substitute for truthfulness. An advertiser cannot simply attach an “AI-generated” label to a materially deceptive claim and assume that the advertisement becomes compliant.

Deepfakes and unauthorised likenesses remain a major concern

One of the most significant areas covered by the framework is the use of real people's identities.

AI tools can now replicate faces and voices with increasing realism. Without adequate safeguards, this can create advertisements that appear to feature celebrities, public figures or ordinary individuals who never participated in the campaign.

ASCI's guidelines make clear that unauthorised replication of a person's likeness is not permitted.

Even where consent exists, the resulting synthetic content may still require disclosure if it materially affects consumer understanding.

When an AI label is not required

ASCI has also tried to prevent over-labelling of ordinary creative and production processes.

Disclosure is generally not required where synthetic technology has no material effect on a consumer's ability to make an informed decision.

This includes routine editing such as:

Colour correction
Basic lighting adjustments
Noise reduction
Standard blemish removal
Minor image enhancements
Decorative or ambient background elements
Obvious fantasy effects that audiences would recognise as fictional
Generation or enhancement of advertising copy
Accessibility-related applications such as subtitles, translations and accurate audio descriptions

For instance, using AI to correct lighting in a product photograph would generally not require a label if the change does not alter the substance of the advertisement or its claims.

Why the distinction matters for advertisers

The framework creates an important distinction between AI as a production tool and AI as a source of potentially misleading representation.

Advertisers increasingly use generative AI throughout the creative process. Requiring a disclosure for every minor AI-assisted edit could make compliance unnecessarily complicated and could potentially reduce the usefulness of labels.

Instead, ASCI has focused on whether synthetic content can materially change what consumers believe about a product, service, person or event.

This approach allows brands to continue using AI for routine creative functions while imposing greater transparency when synthetic content could influence purchasing decisions.

How should the disclosure be displayed?

Where disclosure is required, ASCI permits labels such as:

“Audio/Video created using AI”

“Audio/Video enhanced using AI.”

Advertisers can also use alternative wording provided it accurately communicates the nature of the synthetic content.

The disclosures should follow applicable ASCI requirements relating to disclaimers and should be sufficiently clear for consumers to understand.

Advertisers remain responsible for the final communication

The new framework does not transfer responsibility for an advertisement to the AI tool or technology provider.

ASCI's broader code requires advertisements to be truthful, honest and capable of substantiation where claims relate to objectively ascertainable facts.

That principle continues to apply when artificial intelligence is involved.

Advertisers therefore need to assess the final output rather than assuming that content generated by a third-party AI platform is automatically compliant.

This is particularly important for product claims, testimonials, demonstrations and representations involving real people.

Impact on brands and advertising agencies

The guidelines are likely to require advertisers and agencies to introduce additional checks into their creative workflows.

Campaign teams may need to identify whether an image, video, voice recording or other material has been synthetically generated and then determine whether its use crosses the disclosure threshold.

Large brands using AI-generated influencers, virtual characters or highly realistic product demonstrations could face greater compliance requirements.

Agencies may also need clearer internal approval processes covering consent, intellectual-property rights, factual accuracy and AI disclosure before campaigns are released.

AI advertising enters a new compliance phase

The new framework comes as generative AI becomes increasingly embedded in advertising production.

Brands can now create realistic people, locations, product environments, voices and video sequences without conventional production processes. While these tools can reduce production costs and expand creative possibilities, they can also make it difficult for consumers to distinguish between authentic and synthetic representations.

ASCI's framework attempts to address that problem without requiring every AI-assisted creative asset to carry a disclosure.

ASCI has described its approach as one that keeps consumers at the centre while providing practical transparency requirements where the absence of an AI label could affect how an advertisement is understood.

What advertisers should do next

With the guidelines taking effect after the three-month transition period, brands and agencies should review their AI-related advertising workflows.

Key areas to monitor include:

Whether AI-generated people or voices are used in campaigns
Whether real individuals' likenesses have been replicated with proper consent
Whether synthetic demonstrations show products or features that actually exist
Whether AI-generated locations or events could be mistaken for real ones
Whether sponsored AI recommendations are clearly identified
Whether copyrighted material has been used with appropriate authorisation
Whether AI-generated claims can be substantiated
Whether required disclosures are clear and sufficiently prominent

Market and Business Outlook

The ASCI guidelines are likely to increase compliance requirements for advertisers using generative AI, particularly in high-impact applications such as synthetic influencers, realistic product demonstrations and recreated human identities.

At the same time, the exemption for routine editing, accessibility tools, copy generation and clearly fictional elements means the framework does not treat every use of AI as inherently risky.

For brands, the central issue will be transparency proportional to consumer impact. The biggest compliance risk will not simply be whether AI was used, but whether synthetic content changes what consumers are likely to believe about a product, person or event.

As generative AI becomes a standard part of advertising production, documentation, consent procedures, claim verification and disclosure checks are likely to become increasingly important parts of campaign management.