Research Note
Synthetic Endorsement Disclosure Record
A synthetic-persona campaign can require several different explanations. They should not be collapsed into one vague "AI" badge.
Synthetic Endorsement Disclosure Record
Separate disclosures
A synthetic-persona campaign can require several different explanations. They should not be collapsed into one vague "AI" badge.
| Disclosure question | Record needed |
|---|---|
| What is the audience seeing? | Fictional character, represented person, digital double, generated media, edited media, or mixed production |
| Who operates it? | Creator, studio, brand, agency, human reviewer, and automated system |
| Who is speaking? | Character, actor, authorized representative, or modeled real person |
| What is the commercial connection? | Payment, employment, ownership, free product, affiliate link, family relationship, or another material connection |
| What claim is made? | Express and implied product claims, experience claims, demonstrations, and substantiation |
| Where will it appear? | Feed, image, video, audio, livestream, profile, landing page, repost, and paid placement |
United States guidance
The FTC's Disclosures 101 says material connections should be obvious, hard to miss, and placed with the endorsement. It says video disclosures should appear in the video and that a platform tool may be insufficient on its own.
The FTC's Endorsement Guides questions and answers emphasizes honest, non-misleading endorsements and clear, conspicuous disclosure of unexpected material connections. The 2023 revised guides announcement expressly references virtual influencers.
YouTube separately requires disclosure for certain realistic, meaningfully altered or synthetic content in its creator guidance. Its production label does not replace a material-connection disclosure.
Review boundary
The public guide is issue spotting, not legal advice or campaign approval. Qualified counsel must review the jurisdiction, audience, media, persona rights, testimonial basis, claim substantiation, children or vulnerable audiences, privacy, platform rules, and campaign controls.
The campaign record should preserve approved copy, placement, duration, screenshots or renders, source assets, rights, substantiation, platform settings, review owner, versions, repost handling, monitoring, correction, and withdrawal.
Sources
Follow the evidence.
- support.google.com: 14328491support.google.com
- nature.com: s41586 023 06297 wnature.com
- solomonmg.github.io: bakshy 2015 exposuresolomonmg.github.io
- ftc.gov: federal trade commission announces updated advertising guides combat deceptive reviews endorsementsftc.gov
- FTC Disclosures 101ftc.gov
- support.google.com: 16533387support.google.com
- spec.c2pa.org: Explainerspec.c2pa.org
- youtu.be: GhR9NuCQwlMyoutu.be
- FTC Endorsement Guides questions and answersftc.gov
- support.google.com: 2801947support.google.com
- cor.inquirygroup.org: lateral reading and the nature of expertisecor.inquirygroup.org
- support.google.com: 6342839support.google.com
- newsroom.tiktok.com: how tiktok recommends videos for younewsroom.tiktok.com
- open.spotify.com: 6pC7h1LY88I1LnfvH6h4dvopen.spotify.com
- daltonanderson.ghost.io: ai influencers and the dangers of a filtered realitydaltonanderson.ghost.io