Marketers are increasingly integrating AI tools into workflows, analysis and even creative development. However, regulation is slowly catching up, and disclosure around AI content is now a legal obligation in the EU, with legislation developing across the US and Asia.
Against this backdrop, the IAB has published its AI Transparency & Disclosure Framework V2 aimed at providing brands, agencies, publishers, and technology partners with greater clarity on determining when to disclose.
Advertisers overestimate positive AI sentiment among consumers
The first framework was rolled out back in January this year, but following regulatory developments in recent months and regional variance, the IAB said the framework seeks to provide advertisers, agencies, publishers, platforms and technology partners with what it called a “shared industry baseline for compliance.”
The framework itself highlights a number of industry pain points amid the rise in AI adoption, including inconsistent labelling, mixed consumer expectations, regulatory uncertainty, operational burden, and disclosure trade-offs.
On the latter, the IAB highlighted a disparity between how advertisers perceive consumers receiving AI-generated content and how they actually feel.
According to the organisation, while 82% of advertisers believe consumers feel positive about AI-generated ads, in fact, only 45% of Gen Z and Millennials do — and this gap has grown since 2024, it was shared. In tandem, one study from NYU Stern found that informing consumers that an ad was made with gen-AI decreased CTR by 31.5%.
However, research shared within the framework notes that disclosure is not “uniformly rewarded or penalised.”
Indeed, among the same demographic, 73% said that AI disclosure on an ad would either increase or have no effect on purchasing, with only 27% saying it would make them less likely to purchase.
Advertiser credibility and consumer trust
Here, the framework outlines the crux of its challenge, protecting advertiser credibility while building consumer trust when AI has materially shaped content, with an emphasis on balancing under-disclosure and over-disclosure. With this basis, the framework outlines a definition of materiality, with the threshold being "consumer impact" rather than volume of AI tools used, and highlights the core principles underpinning it as: transparency, proportionality, consistency and clarity.
It specifically calls for targeted disclosure rather than universal labelling — which it says will prevent “disclosure fatigue” and prioritise disclosure where it matters most: where it creates a material risk of misleading audiences about authenticity, identity, or representation.
The IAB highlights high-risk use cases including everything from images and videos generated from prompts and synthetic avatars, to AI chatbots or assistants that could be mistaken for a real person. Meanwhile, on what doesn’t require disclosure, the organisation lists activities like routine post-production, internal workflows, clearly fantastical imagery, and digital twins in standard brand endorsement.
That said, while the framework seeks to establish a “shared industry baseline for compliance,” it does diverge from EU regulation when it comes to authorised digital twins in endorsements and authorised voice clones — which must be labelled under the EU AI Act.
Its reasoning? The framework treats traditional commercial endorsement framing as removing materiality risk. The example it gives here is that a consumer watching a celebrity endorsement understands they are seeing paid commercial messaging, so the use of an AI-generated voice or likeness with the talent's authorisation does not create deception about authenticity.
However, it notes that for advertisers operating in EU markets, EU requirements "take precedence" where they exceed the framework's thresholds.
"Trust is a foundational element which is critical to the growth of AI across the ecosystem. Putting the right transparency and disclosure standards in place benefits everybody: consumers, advertisers, agencies, publishers and platforms," said David Cohen, CEO, IAB, adding: "This is how collective growth happens."
Alongside this transparency framework focused on balancing consumer protection and advertiser priorities, the IAB has also published a framework on measuring visibility in the AI era and is now working on another targeting AI’s role in conversion, according to Digiday.
The publication reported that the framework zooms in on connecting “AI visibility with measuring attribution of ads served to agents,” alongside how AI is influencing marketing. The new framework is due to be published in November.
