As disclosure laws take effect across New York, California, South Korea and the EU, IAB’s updated framework offers advertisers a common playbook.
The Interactive Advertising Bureau (IAB), a trade association for the digital advertising industry, announced Version 2 of its AI Transparency and Disclosure Framework, building on the original version’s guidance for when and how advertisers, agencies, publishers, platforms and technology partners should disclose AI involvement in consumer-facing advertising and marketing content.
“Trust is everything between a brand and its customers, and being honest about AI is part of earning it,” said Caroline Giegerich, vice president of AI at IAB. “That said, not every use of AI needs a label — labeling everything teaches consumers to ignore labels and could negatively impact advertisers. This is why we take a meticulously nuanced position in this framework.”
The Data Behind the Decision
IAB launched the first version of the framework in January 2026, alongside proprietary research conducted with Sonata Insights. The research found mixed consumer perceptions of AI use in creative content — some viewed it positively, others saw it as inauthentic. Despite that split, more than half of respondents said they wanted brands to disclose when an ad was fully AI-generated or used AI imagery or video, and 73% of Gen Z and Millennial respondents said clear disclosure would increase or have no impact on their likelihood to purchase a product.
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Regulatory Momentum
Since IAB published the original framework in January 2026, regulators in the United States, the European Union and parts of Asia have moved from proposal to enforcement. New York’s synthetic performer law, signed in December 2025, took effect in June 2026. California’s SB 942, which introduced metadata and labeling requirements, took effect Aug. 2, 2026. South Korea’s revised AI Basic Act imposed AI labeling mandates earlier this year. In the EU, Article 50 of the AI Act took effect Aug. 2, 2026, and the European Commission published its final Code of Practice supporting that law — a voluntary compliance framework developed with input from industry, academia and EU member states — in June 2026.
IAB says the framework is intended to represent the advertising industry’s perspective, not to replace state or international regulation, which takes precedence over industry self-regulation. As jurisdictions adopt different disclosure thresholds and formats, the framework is meant to give advertisers, agencies, publishers, platforms and technology partners a shared industry baseline, rather than requiring a jurisdiction-by-jurisdiction approach.
Balancing Under-Disclosure and Over-Disclosure
The framework calls for targeted disclosure rather than universal labeling, particularly where AI use materially affects authenticity, identity or representation in ways that could mislead consumers. It recommends disclosure for high-risk use cases including images and videos generated from prompts, some synthetic voices, synthetic avatars, digital twins of deceased individuals, digital twins of living individuals placed in fabricated situations outside standard brand endorsement, and AI chatbots or assistants that could be mistaken for human representatives.
It also outlines what does not require disclosure: routine post-production, internal workflows, clearly fantastical imagery, authorized synthetic voices of real individuals, generic synthetic voices, background music, standard audio enhancement, digital twins used in standard brand endorsement, obvious cartoon or stylized avatars, and text or copy.
“The working group’s central challenge was avoiding two failure points,” Giegerich said. “Under-disclosure leaves consumers at risk of being misled. Over-disclosure could risk negatively impacting advertisers.”
An Open Approach to Labeling
In the U.S., advertisers can choose between a standardized icon or a clear text label; either fully satisfies the framework’s disclosure recommendation, letting advertisers select the method best suited to the format and placement.
Advertisers operating in the EU face an evolving landscape under the AI Act. Article 50’s transparency obligations became binding Aug. 2, 2026, requiring disclosure of AI-generated content and deepfakes, though the article does not prescribe a specific icon. The accompanying Code of Practice, finalized in early June 2026, is voluntary; it sets design and placement guidance for AI labels and includes illustrative examples of a possible common EU icon that has not yet been finalized.
The framework also includes accessibility requirements for its standardized label.
“Trust is a foundational element critical to the growth of AI across the ecosystem,” said David Cohen, CEO of IAB. “Putting the right transparency and disclosure standards in place benefits everybody: consumers, advertisers, agencies, publishers and platforms. This is how collective growth happens.”
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From the Working Group
“Regulators in New York, California, South Korea and the EU are no longer asking whether AI disclosure matters — they’re setting enforceable rules for it,” said Graham Wilkinson, executive vice president, chief innovation officer and global head of AI at Acxiom. “An industry framework that keeps pace with that shift, rather than reacting to it state by state, is what lets us keep innovating without leaving consumers or regulators guessing.”
“There is data that shows consumers are open to trusting AI in advertising, but only when brands are upfront about it,” said Michael Lampert, senior director of global gen AI adoption and consumer data strategy at Mondelēz International. “As adoption accelerates across the industry, that gap between AI use and consumer trust is the one this framework is built to help close.”
“Agencies sit at the center of this conversation, translating this framework into what actually runs in-market for our clients,” said Simon Poulton, executive vice president of innovation and growth at Tinuiti. “Having clear, consistent guidance on disclosure means less guesswork and less risk for the brands we represent, and that benefits the entire industry.”
“Trust and transparency are foundational to our work at The Weather Company, including how we build ad experiences,” said Brian Hull, head of global creative labs at The Weather Company. “Integrating IAB’s AI Transparency and Disclosure Framework into our creative workflow allows us to provide brand partners with clear, standardized guardrails and enterprise-grade safety at scale. We’re proud to collaborate with IAB to continue championing responsible AI governance across the industry.”
The AI Transparency and Disclosure Framework V2 is available to review on IAB’s website, alongside the original V1 framework.
