ASC Circular 2026-014A–Supplemental Guide to ASC Circular No. 2026-014; Guidelines on the Use of Artifical Intelligence in Advertising
This Supplemental Guide is issued to provide a brief and practical clarification of ASC Circular No. 2026-014,“Guidelines on the Use of Artificial Intelligence in Advertising.” It is intended to assist advertisers and agencies in understanding when the use of AI calls for disclosure.
AI may be used as a creative or production tool in advertising, such as for drafting copy, generating ideas, editing images, removing backgrounds, or assisting in post-production.
To be clear, the use of AI in advertising materials does not automatically require the presence of a disclosure.
An AI DISCLOSURE is required when AI is used to create, replace, or materially alter ad content or elements where the ad content or execution is covered by or requires documentation because of an existing law, government regulation, permit, consent, authorization, or similar requirement. The disclosure phrase can be “AI-generated,” “AI-assisted,” or “Created with AI.”
For example:
| Example of AI Use | When AI Disclosure is Required | Remarks & Reminders |
|---|---|---|
| AI-generated child | When an AI-generated child is used in place of an actual child and the use of an actual child would require a DOLE permit. | The disclosure should appear in the relevant frames or layout where the AIgenerated child appears. |
| AI-generated celebrity or identifiable person | When a celebrity or identifiable person is depicted through AI-generated content without the person's actual participation, where the use of the person's name, image, likeness, or voice requires onsent or authorization. | AI disclosure does not replace the required consent, authorization, endorsement, or other documentation. The Advertiser or Agency must secure the necessary documentation, such as a contract or notarized affidavit of the endorser, and submit it to the ASC for validation. |
| AI-generated image of an existing structure | When an AI-generated image depicts an existing structure whose use or showing would require authorization from its owner. | The Advertiser or Agency remains responsible for securing the necessary authorization from the structure owner. This documentation need not be submitted to the ASC with the clearance application. |
| AI-generated sound, music, track, or similar element | When AI is used to create or materially alter such elements based on existing material for which authorization or other documentation would otherwise be required. | The Advertiser or Agency remains responsible for securing the necessary documentation from the owner or originator. |
The disclosure phrase should use either Arial or Tahoma font for readability, with a size of 12 points minimum or based on common visual sense, depending on the overall scaling of the disclosure phrase to the size of the material. The disclosure phrase should be readable against the background in which it is being placed. Placement of the disclosure phrase shall be left to the discretion of the advertiser, agency, or creator.
The same principle applies to other persons, property, or subjects whose use in advertising is subject to any legal, regulatory, contractual, or similar requirements and does not remove the need to secure documentary requirements. Advertisers are enjoined to continue to observe applicable rules concerning:
- identifiable persons and endorsements;
- intellectual property;
- protected property; to name a few.
Routine or incidental use of AI for production purposes—including ideation, drafting, editing, enhancement, post-production, compositing, animation, background generation, audio processing, and similar functions—does not require disclosure, provided that none of the disclosure conditions (as stated above) under these Guidelines, are present.
In gist, the advertiser remains responsible for the final advertisement, whether it was created by a person, by AI, or through a combination of both. AI-generated or AI-assisted content must still comply with applicable laws, regulations, and ASC standards.
For the complete provisions, refer to ASC Circular No. 2026-014, “Guidelines on the Use of Artificial Intelligence in Advertising.”