The new framework requires disclosure for AI-generated influencers, synthetic product demonstrations and sponsored recommendations, while routine editing and accessibility applications remain exempt. The Advertising Standards Council of India (ASCI) has introduced a new framework governing the use of synthetically generated content (SGC) in advertising, laying down clearer rules on when brands need to disclose AI-generated elements and which applications remain prohibited.
The Guidelines for Responsible Labelling of Synthetically Generated Content in Advertising follow stakeholder consultations on a draft released in May. They are designed around the potential impact of synthetic content on consumers rather than the technology used to create it. The guidelines will take effect three months after publication.
Under the framework, synthetic content can raise concerns when it creates unrealistic expectations, presents unsafe situations, exploits vulnerable groups, uses an individual’s likeness without consent, or communicates false or misleading information. Advertisements using SGC will continue to be evaluated under the ASCI Code in its entirety.
AI labels do not override existing advertising rules
ASCI has clarified that adding an AI disclosure does not make an otherwise non-compliant advertisement acceptable. Fabricated endorsements or testimonials, misleading synthetic depictions of product results or features, fake locations presented as real, unauthorised copyrighted material, deepfakes and the unauthorised use of an individual’s likeness remain prohibited. The framework therefore treats transparency and advertising compliance as separate requirements. An advertiser cannot rely on an AI label to legitimise content that already violates the ASCI Code.
When brands must disclose AI-generated content
Disclosure becomes mandatory when synthetic content can materially influence a consumer’s decision and withholding that information could affect their understanding of an advertisement. This includes synthetically generated influencers or ambassadors, as well as the use of a real person’s likeness or voice with consent for personalised messaging. Advertisers must also disclose fabricated events or settings when they could influence how consumers understand a product or service.
The requirement extends to demonstrations involving products that do not currently exist and AI-generated sound effects that are particularly relevant to a product’s core features. For example, synthetic audio used to demonstrate a headphone’s performance could require disclosure. AI-generated product recommendations that are paid for or sponsored also require a specific disclosure: “Sponsored by [Brand]”.
What does not require an AI label?
Not every use of AI in advertising will require disclosure. The guidelines exempt applications where synthetic content does not materially affect a consumer’s ability to make an informed choice. This includes routine post-production work such as colour correction, lighting adjustments, noise reduction and minor blemish removal. Decorative or ambient elements and effects that are clearly fantastical are also outside the mandatory labelling requirement. The framework further excludes administrative and text-based applications such as generating advertising copy, along with accessibility uses including subtitles, translations and accurate audio descriptions.
ASCI outlines acceptable disclosure formats
For content that does require disclosure, advertisers can use labels such as “Audio/Video created using AI” or “Audio/Video enhanced using AI.” Platform-provided labels can also be used. ASCI allows alternative wording provided it accurately communicates the nature of the synthetic content to consumers. Where applicable, these disclosures must also comply with the ASCI Code’s requirements around disclaimers.
Commenting on the framework, Manisha Kapoor, Secretary General and CEO, ASCI, said, “The use of AI in advertising is evolving rapidly, and our approach must evolve with it while keeping the consumer at the centre. These guidelines provide for practical transparency requirements when a consumer’s understanding of an advertisement may be adversely impacted without an AI label. Importantly, it clarifies where the mere use of an AI label may not make an otherwise misleading advertisement acceptable. The responsibility remains with advertisers to ensure that the end communication is honest, transparent and compliant with the ASCI Code.”
The new guidelines establish a distinction between AI use that simply assists the advertising process and synthetic content that could materially alter how consumers perceive or evaluate an advertisement. All advertising using SGC will continue to be assessed against the ASCI Code as a whole.
