Synthetic People Disclosure Research Note

Synthetic People Disclosure Research Note

The brand guide can move from research hold to ready because the public draft now limits itself to a review framework, distinguishes jurisdictions, cites current primary sources, and states that it is not legal advice.

FTC staff says the Consumer Reviews and Testimonials Rule does not categorically prohibit AI-generated stock avatars or virtual influencers. An avatar may still present a testimonial. The underlying testimonial cannot be fake or false, and the use can still be deceptive under the FTC Act. An unauthorized celebrity avatar can violate the rule when reasonable consumers would think the celebrity gave the testimonial.

FTC material-connection guidance remains a separate disclosure layer. Identifying a character as synthetic does not disclose sponsorship.

YouTube requires creator disclosure when meaningfully altered or synthetically generated content appears realistic. Covered examples include making a real person appear to say something they did not say and generating a realistic scene that did not occur. This platform field does not replace campaign-level disclosure or consent.

The EU AI Act generally applies from August 2, 2026. Article 50 includes transparency duties for certain AI-generated or manipulated image, audio, and video content, with a limited approach for evidently artistic, fictional, creative, or analogous works. A campaign reaching the European Union needs current legal review.

UK advertising rules require testimonials and endorsements to be genuine unless obviously fictitious and supported by documentary evidence. A photorealistic avatar can create an audience-impression question even if production calls it fictional.

Operational distinction

Review synthetic identity, real-person likeness or voice, material connection, testimonial or experience, ordinary product claims, market rules, and platform rules separately. One "AI used" label cannot resolve all of them.